Making Molehills out of Mountains A common sense approach to the Metals Moratorium

1. Making Molehills out of MountainsA common sense approach to the Metals Moratorium George Goode Manager Environmental Protection Division August 19, 2009

2. 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

3. 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

4. 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

5. Moratorium Metals Handling Flowchart 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)? Metal items are within a ‘Radiological Area’ Yes No No Process Knowledge confirmed by HP Survey Yes Yes Moratorium Metal Free-Release Survey by Radcon Background levels Reuse on-site for intended purpose Reuse within DOE Disposal (Subtitle D Landfill) No Rad Waste >Background levels Clean Scrap Metal (unrestricted use)

6. 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