Making Molehills out of MountainsA common sense approach to the Metals Moratorium

George GoodeManager

Environmental Protection DivisionAugust 19, 2009

Brief History of the Metals Moratorium

January 2000: Secretary of Energy Richardson issued a moratorium on release of volumetrically-contaminated metals pending a decision by NRC to establish national standards.

July 2000: DOE Metal Suspension suspends the unrestricted release for recycling of scrap metals from radiation areas within DOE facilities• The suspension applies to the release of metal from “radiological

areas” as defined by 10CFR835 Originally expected to be resolved within one year Policy remains in effect currently

• Technical, political, and stakeholder issues have confounded resolution to date

Results Initially: Confusion and establishment of inconsistent programs

• Metals within radiological areas subject to different set of rules than all other materials (wood, plastic, concrete, etc still release under 5400.5)

Financial: Turned an asset (scrap metal) into a liability Regulatory: Solid waste regulations, storm water runoff

concerns, speculative accumulation issues, disposal uncertainty On the Ground: Mountains of ‘moratorium metal’ taking up

valuable space• BNL (2008): 13,500 ft3 (disposed at a cost of $130,000)• SLAC (2007): 27,000 ft3

• Some sites disposing, others accumulating

Path Forward Around the Complex:

• DOE is beginning to evaluate site programs- Documenting best practices- Goal to develop consistency across the complex- Sharing lessons learned- Developing stakeholder confidence to enable policy reform

• DOE 5400.5 (DOE 458.1) and/or DOE G 441.xx ‘Authorized Release’ process?

At BNL:• Approach similar to the program developed for the Hazardous Waste

Moratorium of the 1990’s• Documented program• Combination of Process Knowledge and Surveys• Common sense approach: applies only to the subset of radiological

areas where the real potential for contamination or activation exists- Contamination, High Contamination, Airborne, and Radiation Areas where

the potential exists for Activation

Metal items are within a

‘Radiological Area’

Clean Scrap Metal(unrestricted use)

Free-Release Survey by Radcon

Rad Waste

Moratorium Metal

No

>Background levels

Background levels

Yes

Yes

Moratorium Metals Handling FlowchartNo

Item(s) exposed to a beam or other source of particles CAPABLE OF CAUSING ACTIVATION(Radiation Areas w/ activation check required)?

Item(s) within an area where CONTAMINATION EXISTED due to the presence of unencapsulated or unconfined Radioactive Material (Contamination/High Contam./Airborne Rad Areas)?

No

Yes

Process Knowledge confirmed by HP Survey

Reuse on-site for intended

purpose

Reuse withinDOE

Disposal (Subtitle D Landfill)

Path Forward Considerable momentum building around the DOE Complex

• Raised by Lab Directors with Secretary Chu• HS-22 evaluating site approaches, documenting best practices• NNSA (R. Meehan, NA-50) visiting NNSA sites to evaluate

programs, identify opportunities, document best practices• SC starting to become engaged in process to develop solution

Sites should designate a lead and engage in this process NOW

Mountains

Molehills