Making Molehills out of Mountains A common sense approach to the Metals Moratorium George Goode Manager Environmental Protection Division August 19, 2009
Jan 20, 2016
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 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 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