RE: DOE loses DNRC lawsuit against plan to put 'low levels' of Cs-137into grout.

[Susan, L, Gawarecki]

The following is a quote from a colleague who has been following the 

issue in connection with paid work.  I'm withholding the name as this 

person works for DOE.



<<DOE's original arguments on the need for an "incidental to

reprocessing" waste classification were quite reasonable, I think.

That is, there is reprocessing residue adhering to waste tanks and

other equipment that is all but impossible to remove, and the risks

and costs of getting it all out of the ground greatly exceed the

risks of stabilizing some of it in situ, so it deserves to be

considered "low level waste" (as it would be if it were gloves

worn by workers handling the equipment).



Unfortunately, the current administration got greedy and decided

that if the unremovable residue is "incidental waste" that can be

left in situ for reasons of high cost and impracticability, it

ought to be possible to handle much of the tank waste as low-level

waste because it costs so much money to handle it as high-level waste.>>



DOE is looking for a way to accelerate the cleanup of the radioactive 

messes it has left in the wake of R&D and production of bombs. 

Unfortunately, this is inherently an extremely difficult and expensive 

process, especially if DOE truly intends to meet the terms of agreements 

with the involved states.  Now it seems that DOE wants to change those 

agreements, but it has not had any success in convincing communities in 

Washington, South Carolina, and Idaho that these tanks full of waste can 

be safely closed in situ.



I think a major part of the country's waste management problem is that 

it deals with radioactive (and also hazardous) wastes based on 

administrative definitions (how generated, when generated, generated by 

whom, exclusions, etc), not necessarily on actual composition and 

properties.  The latter should be readily translated into risk based on 

existing conservative models.



In Oak Ridge we've seen successful and innovative tank closures.  The 

community has agreed to a state-of-the-art landfill to contain cleanup 

and D&D wastes, with a risk-based waste acceptance criteria.  Integral 

to decisions on these issues was in-depth community involvement.  I 

believe this is a major factor in the progress and success enjoyed by 

Oak Ridge's cleanup, not to mention enormous cost savings.



An important factor in all of this is that risks are clearly explained 

to the community, based on engineering design, models of long-term 

releases, and biological and other factors.  Oak Ridge has two formal 

oversight groups--the site-specific advisory board and the LOC's 

Citizen's Advisory Panel.  In addition, unaffiliated members of the 

community often show up to express opinions.  Our meetings with DOE and 

the regulators get down to details, and the agencies are challenged to 

prove their points.  If they do, the community is typically accepting of 

the decision.



Oak Ridge is blessed with lots of retired technical people who are 

looking for a way to contribute.  It took DOE a long time to accept this 

interest as a genuine concern that the agency does the cleanup right, 

but they've seen time after time that addressing the concerns of the 

community is repaid many times over.



Susan Gawarecki

-- 

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

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

Oak Ridge Reservation Local Oversight Committee

102 Robertsville Road, Suite B, Oak Ridge, TN 37830

Toll free 888-770-3073 ~ www.local-oversight.org

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





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