Making Molehills out of Mountains A common sense approach to the Metals Moratorium George Goode Manager Environmental Protection Division August 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 )  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 ft 3 (disposed at a cost of $130,000) SLAC (2007): 27,000 ft 3 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 (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 Moratorium Metals Handling Flowchart No 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 within DOE 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