Product Stewardship

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Product Stewardship

• Woodrow Wilson International Center for Scholars
• June 25, 2003

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Todays Agenda

• Product Stewardship Overview
• Radioactive Materials Project
• Potential Solutions, Challenges
• Other Product Stewardship Efforts
• Questions, Answers, Discussion

Scott Cassel
Greg Morose
Tom Balf
Scott Cassel
All
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What Is Product Stewardship?

• Product-based approach to environmental
  protection
• Goal reduce the health and environmental impacts
  throughout life of products
• Often involves partnerships

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Examples of Product Stewardship

• Product take-back program or recycling system
• Design for environment
• Consumes less energy
• Uses less material
• More recyclable material
• Recycled content
• Substituting toxic materials with non-toxic
  materials
• Environmentally preferable procurement

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Product Life Cycle Approach
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Why Product Stewardship?

• Paradigm shift in waste management
• Address industry unfunded mandate
• Solve local collection program dilemma
• Sustainable financing system
• Shift Costs from Taxpayers to Consumers
• Shift Costs from Back-end to Front-end (Purchase
  Price)
• Product design changes

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Product Stewardship Institute

• Founded in December 2000
• Based at the University of Massachusetts/Lowell
• Coalition/Affiliate Members
• Agency leaders pledge to work with PSI on product
  stewardship issues
• 26 State members
• 23 Local agency members

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Product Stewardship Institute

• Mission
• To assist state and local government agencies in
  establishing cooperative agreements with industry
  and developing other initiatives that reduce the
  health and environmental impacts from consumer
  products.

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PSI Current Projects

• Electronics (computers, TVs)
• National Electronics Product Stewardship
  Initiative
• Model State Electronics Legislation
• Government Procurement Officials Guide to
  Purchasing Environmentally Preferable Computers
• Pilot Computer Take Back with Major Retailer
• Paint
• National Paint Product Stewardship Initiative
• Benjamin Moore Pilot Take Back

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PSI Current Projects

• Pressurized Gas Cylinders (Dialogues)
• Refillable Propane Tanks
• Non-refillable Small Gas cylinders
• Radioactive Materials Product Stewardship Project
• Mercury (thermostats)
• Tires

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Other Product Stewardship Initiatives in the U.S.

• Beverage containers
• Mercury products
• Rechargeable Batteries
• Used Oil
• Auto batteries
• Carpet

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PSI Product Stewardship Principles

• Shared Responsibility
• Internalize Costs
• Incentives for Cleaner Products
• Flexible Management Strategies
• Clear Roles and Responsibilities

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Product Stewardship A New Waste Management
Paradigm
VOLUNTARY
MANDATORY
NEGOTIATED
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Radioactive Materials Project
Goals Undertake a product stewardship approach
to reduce the health and environmental impacts
associated with nuclear fixed gauges and tritium
exit signs. Provide a framework for future
efforts to manage other devices containing
radioactive materials. Funding

• EPA Office of Radiation Indoor Air

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Project Phases

• Phase 1 Outreach, Research (10/02 4/03)
• Phase 2 Convene Dialogue (5/03 4/04)
• Phase 3 Implementation (5/04 10/04)
• Phase 4 Monitor Results (11/04 10/05)

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Products with Radioactive Materials
Specific License General License Exempt
Irradiators, portable gauges, teletherapy,
radiography, etc.
Fixed gauges, static eliminators, exit signs, in
vitro testing, etc.
Smoke detectors, self-luminous devices, radiation
instruments, etc.
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Regulatory Requirements GL Devices

• General Requirements
• Labeling
• Responsible Individual
• Proper usage
• Leak testing
• Reporting
• Lost, stolen, broken
• Corporate change
• Storage limitation (2 yrs)
• Proper disposal
• Shall not abandon

• Annual Registration of Certain GL Devices
  containing greater than
• 10 mCi of cesium-137
• 0.1 mCi of strontium-90
• 1 mCi of cobalt-60
• 1 mCi of transuranics (americium-241)
• Annual fee

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Product Life Cycle
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Key Stakeholders

• Government EPA, State Radiation Programs, etc.
• Professional Organizations CRCPD, NCRP, etc.
• Industry associations ISRI, SRI, NADC, etc.
• Disposal facilities Barnwell S.C., Richland, WA
• Manufacturers SRB, Isolite, Ohmart/Vega, etc.
• Waste Broker Duratek

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Tritium Exit Signs

• Operation Phosphorus in glass tubes is
  illuminated by tritium radiation, requires no
  electricity
• Source activity Tritium is a low energy, beta
  emitter
• Costs Approximately 125 - 350 per sign

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Tritium Exit Signs - Market

• Quantity Approximately 2 million installed in
  U.S.
• Annual Sales 80,000 110,000 per year
• Locations Hospitals, schools, factories, etc.
• Advantages Low installation cost, low
  maintenance costs, reliability
• Alternatives LED, photoluminescent,
  electroluminescent, incandescent, etc.

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Nuclear Fixed Gauges

• Operation Used to monitor/measure density,
  thickness, and other parameters during
  manufacturing processes.
• Source Various radiation sources such as
  Am-241, Cs-137, etc. (neutron, gamma, beta
  emitters).
• Costs Approximately 3,000 - 8,000 per gauge
  (total systems may cost up to 1.5 million).

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Nuclear Fixed Gauges - Market

• Annual Sales Approximately 1,500 7,000 GL
  devices per year
• Applications Various manufacturing
  applications including materials processing,
  beverage, and paper
• Advantages Proven technology, low maintenance,
  and high reliability
• Alternatives Infrared, laser, ultrasonic,
  capacitance, and microwave

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End of Life Management

• Manufacturer take-back/recycling Signs 0 to
  100, Gauges 0 to gt1,000
• LLRW Disposal Facilities Barnwell, SC
  Richland, WA
• CRCPD Orphan Program 8 states participating
• Off-site Recovery Program DOE LANL
• Lost, stolen, abandoned, solid waste stream,
  scrap metal

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NMED Incidents

• GL Nuclear Fixed Gauges
• 278 reportable incidents
• 53 equipment problems
• 33 lost or stolen
• Only 20 at GL Device Licensees
• 3 radiation overexposures at GL Device Licensees
• Maximum exposure was 32 rem to an extremity

• Tritium Exit Signs
• 83 reportable incidents
• 53 lost or stolen
• 15 broken or damaged capsule
• 14 incidents in which exposures occurred
• Maximum exposure was 286 mrem

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Issue Summary

• Devices become unwanted, abandoned, lost, stolen,
  damaged, or improperly disposed
• Environmental hazard
• Human health risk
• Costs to cleanup contamination (steel mill up to
  30 million)
• Gauges are a potential source of radioactive
  material for dirty bombs

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Prioritization Matrix
1
2
3 - 4
2 - 3
3
2
1
2
1
1
1 - Minimal or no concern 2 - Some concern
3 - Moderate concern 4 - High concern
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Product Stewardship Examples

• Manufacturer take-back responsibility
• New NRC registration process responsibility
• Orphan program responsibility, roles
  relationships
• Iowa DPH responsibility, roles relationships,
  incentives, flexible management systems

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Advancing Change
Where we want to be Identifying a shared need
and shaping a future vision
Where we are now PSI Research Report
Where they were
Where we were pre orphan program and NRC
Registration
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Future Vision

• Accurate information (registration, sales,
  recycling rates)
• Accountability for devices (existing, disused,
  and orphan)
• Compliance with applicable standards and
  regulations
• Proper incentives in place

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Future Vision

• Minimization of radioactive material use
• Elimination of scrap metal contaminants
• Proper education and information regarding
  management
• Nationwide harmonization of standards and
  regulations

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Product Stewardship Principles - Gaps

• Incentives for manufacturing and sales of
  non-nuclear fixed gauges
• Cost shifting from users to taxpayers and scrap
  industry
• Education of demolition industry regarding
  radioactive device management

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Challenges

• No industry association to provide industry-wide
  data or to represent coordinate efforts of
  manufacturers/distributors
• No threat of pending state or federal producer
  responsibility legislation to provide impetus for
  action
• Attaining a sustainable financial model to
  implement and maintain solutions

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Potential Solutions Initial Focus

• Increase device recycling rates by enhancing
  existing manufacturer take back system
• Increase radioactive material education for the
  demolition industry
• Increase usage of non-nuclear alternatives

Gauges, Signs
Gauges, Signs
Gauges
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Next Steps

• Leverage product stewardship models/solutions
  from other PSI initiatives
• Tie in results from other EPA efforts
  (alternatives study, and cesium materials
  balance)
• Conduct stakeholder survey
• Design and implement the dialogue process
• Develop and implement the stakeholder action plan

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Other PS Projects Goal Similarities

• Decrease the use of toxic/radioactive materials
  (e.g. alternative designs)
• Increase collection and recycling rates
• Increase the purchase of alternatives
• Need for a sustainable financing mechanism

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Other PS Projects Other Similarities

• End of life management cost versus value
• Steel industry involvement (steel housing
  enclosing toxic/radioactive material)
• Closing the toxic/radioactive materials loop
• Design dialogue process to meet specific needs of
  the project

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Other PS Projects Differences

• Consumer versus industrial focused (major retail
  entities as stakeholders)
• More state/local agency focused with less federal
  agency involvement
• No terrorism/security issues present

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Other PS Projects - Differences

• Existing industry associations as stakeholders to
  provide critical project assistance
• NGO and pending state legislation drivers
  (electronics project)
• PSI represents governments for NEPSI process, PSI
  developing dialogue forum for radioactive
  materials/other products

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Contact Information

• Product Stewardship Institute
• University of Massachusetts/Lowell
• Tel [phone]
• www.ProductStewardship.us