Correspondence to DOE Secretary Richardson

Oak Ridge Reservation Local Oversight Committee, Inc.

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LOC correspondence
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LOC concerns regarding suspension of release of potentially contaminated scrap metal for recycling from DOE facilities
LOC concern regarding suspension of nickel recycling at K-25 Site, Oak Ridge Reservation, Tennessee

July 20, 2000

Mr. Bill Richardson
Secretary of Energy
U.S. Department of Energy Headquarters
Forrestal Building
1000 Independence Ave., S.W.
Washington, DC 20585

Subject: LOC concerns regarding suspension of release of potentially contaminated scrap metal for recycling from DOE facilities

Dear Secretary Richardson:

The Board of the Oak Ridge Reservation Local Oversight Committee, Inc., (LOC) is concerned about the impact of the recently announced DOE moratorium on the release for commercial recycling of metals that have surficial residual radioactivity. The financial impact of the moratorium has the potential to seriously damage the Oak Ridge region's already weak economy.

The reindustrialization of the former K-25 site—now known as East Tennessee Technology Park (ETTP)—requires the decontamination and decommissioning of several large gaseous diffusion process buildings. In order to accomplish this cleanup, vast quantities of metal are to be removed from the facilities. A significant percentage of this metal will meet acceptable release levels under current Nuclear Regulatory Commission (NRC) guidance after decontamination. The recovery value of the metals is not great (estimated at $12 million), but the cost of disposing of these metals as radioactive waste is enormous, and the potential environmental benefits of resource recovery will not be realized. The State of Tennessee will not allow DOE to stockpile this metal in scrap heaps, a past practice that reflects poor waste management. To force Oak Ridge Operations (ORO) to ship this material to Envirocare in Utah or the Nevada Test Site for disposal instead of allowing commercial decontamination and recycling of the metal will impose a huge financial burden on the ORO Environmental Management program. The significant cost increases that this measure would impose on ongoing cleanup projects at ETTP would necessitate either diversion of funds from other important environmental management activities (thus delaying the entire cleanup process for the Oak Ridge Reservation) or substantial increases in funding for environmental management efforts here. Can ORO's EM program expect a commensurate increase in their fiscal year 2001 funding allocation from Headquarters to offset these additional costs?

The LOC strongly supports the promulgation of federal regulations to establish clear and unambiguous authority for the free release of metals and other materials with minimal amounts of residual radioactive contamination. Nuclear Regulatory Commission regulatory guidance regarding release of metals with residual surface radioactivity cannot substitute permanently for a promulgated rule. The LOC Board urges your department to work aggressively toward promulgation of formal regulations on this matter.

The LOC feels that this unilateral moratorium by DOE will not affect the continued release of surface-contaminated material by the private sector, but it will do serious damage to the Oak Ridge cleanup process that is vitally important to DOE's and our communities' efforts to offset the adverse economic consequences of DOE downsizing in our region.

Please ensure that the LOC is kept informed regarding the activities DOE is undertaking with respect to the metals recycling issue. In past correspondence (our letter to you of April 24, 2000) we specifically requested copies of minutes of the periodic meetings of the Re-use and Recycling Task Force along with any recommendations generated by the Task Force. To date we have not received any of the requested material.

Sincerely,

Jerry Kuhaida
Mayor, City of Oak Ridge, and
Chair, Local Oversight Committee

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April 24, 2000

Mr. Bill Richardson
Secretary of Energy
U.S. Department of Energy Headquarters
Forrestal Building
1000 Independence Ave., S.W.
Washington, DC 20585

Subject: LOC Concern Regarding Suspension of Nickel Recycling at K-25 Site, Oak Ridge Reservation, Tennessee

Dear Secretary Richardson:

The Board of the Oak Ridge Reservation Local Oversight Committee, Inc., (LOC) is concerned about the impact of the recent DOE decision to curtail commercial recycling of metals that volumetrically contain any amount of residual radioactivity.

The current situation is of concern to the LOC because the inability to market material with de minimis contamination is stymieing important environmental initiatives for our region. As you are aware, recycling of decontaminated nickel was to have played an important role in financing the remediation of gaseous diffusion facilities at Oak Ridge's K-25 site, so the moratorium on release of this material will inevitably delay the cleanup and industrial reuse of these buildings.

This region, and the nation, urgently needs criteria to allow release of materials that contain residual radioactivity at levels that have been determined to be safe. The DOE should work closely with NRC to develop a reasonable standard for release of volumetrically contaminated metals, which NRC can then promulgate as a rule.