Re: DOE scrap metal

[Susan Gawarecki <loc@ICX.NET>]

DOE has published a Notice of Intent to Prepare a Programmatic

Environmental Impact Statement on the Disposition of Scrap Metals.  This

is found beginning on page 36562 of the Federal Register for Thursday,

July 12, 2001, Vol 66, No. 134.  Comments are due September 10.



My Citizens' Advisory Panel has given preliminary approval to comments,

which I've summarized below:



1. The PEIS should consider disposition of scrap metals with volumetric

contamination, not just surface contamination. 



2. The PEIS should be delayed in order to incorporate any

recommendations that are developed by the Nuclear Regulatory

Commission/National Academy of Sciences study regarding "de minimis"

release levels for surface and volumetric contamination.  This study is

due to be released in February 2002.



3. The PEIS should be expanded to consider other specific metals such as

nickel.



4. Clarify the reference to intended version of DOE Order 5400.5.



5. The Notice of Intent is inconsistent in how it refers to quantities

of metals; this should not be carried through to the PEIS.  The focus is

on volume of metals, but quantities are given as weights.  Perhaps a

better measure would be to use the values of the metals on the recycling

market on a given date, to present a more accurate comparison of costs

and benefits.



6. DOE should recognize the role of decontamination and independent

verification of degree of residual radioactivity as acceptable means of

bringing metals to a recyclable condition.  The actual residual

radioactivity of the metal, not the fact of its origination from a

radiological area, should be the parameter by which its ability to be

recycled is judged.



7. Alternative 2 should be revised where it refers to alternative

standards.  The case "indistinguishable from background" is not an

existing alternative radiological criteria promulgated by the

organizations listed in the Federal Register notice (Volume 66, Number

134, Page 36564) and should be a new stand-alone alternative. 



8. State assumptions as to how "background radiation" is defined.



9. Compare the quantities and potential release levels of DOE metals

under consideration to those that already enter the recycling stream

from the commercial nuclear industry, generators of NORM-contaminated

materials (e.g. the oil and gas industry), and from overseas.



10. Clearly distinguish the type, nature, and intensity of radioactivity

associated with metals contamination in the nuclear weapons complex from

that associated with sources from medical and testing industries.  The

latter are a serious concern in the scrap metal stream, but should not

be confused in the public's mind with the low-level residual

contamination under consideration in this PEIS.



11. The true cost of considering the various alternatives must be

calculated, including the cost of storing and/or disposing of the metal,

including the impacts on burial site capacity.  The cost-benefit

analysis must include the impact on cleanup of a site based on budget

resources and the potential benefit of offsetting remediation costs with

the value of the metal.



12. Analyze the environmental and health impacts of mining, smelting,

and transportation of equivalent volumes of otherwise virgin metals in

comparison to the risks from decontamination and recycling of strategic

metals.



13. Risks from decontamination and recycling must be compared to risks

from disposal of contaminated metals, including transportation risks.



14. State assumptions behind any exposure models used to calculate risk,

especially whether these are based on "linear no-threshold" assumptions

or if a threshold is assumed, state that exposure level.



These may undergo further slight modification, but in general they

accurately reflect the opinion of the LOC's Citizens' Advisory Panel.



Regards,

Susan

-- 

.....................................................

Susan L. Gawarecki, Ph.D., Executive Director

Oak Ridge Reservation Local Oversight Committee

                       -----                       

A schedule of meetings on DOE issues is posted on our Web site

http://www.local-oversight.org/meetings.html - E-mail loc@icx.net

.....................................................

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