According to the National Environmental Policy Act, or NEPA, a federal agency must evaluate the potential environmental impact of any significant action. Major actions normally require an Environmental Impact Statement (EIS), while more routine projects are typically evaluated in a less-detailed Environmental Assessment (EA).EISs and EAs are documents prepared for the public as well as for agency decision-makers. They help concerned stakeholders understand the implications of federal decisions.

NEPA documents are meant to ensure that proposals receive appropriate scrutiny for all aspects of their potential impact on the human environment. This scrutiny is not limited to matters such as ecology and pollution; it also includes economic impacts, effects on historical sites, and other quality-of-life issues. A cost-benefit analysis may also be included.

Unfortunately, recent NEPA documents prepared for DOE proposals in Oak Ridge have been less than adequate. In the case of the Spallation Neutron Source EIS, for example, much of the information was either outdated or completely in error, and detailed comments were required from interested members of the community to set the record straight.

The stakeholder community assumed the weakness of this document was an aberration, but the recent draft EIS on managing ORNL's transuranic waste suffered from similar deficiencies. And so did the recent draft EA on the proposed lease of Parcel ED-3, a proposed parcel for development by CROET near East Tennessee Technology Park.

LOC and CAP members have concluded that DOE's contractor for NEPA documents must have cut-and-pasted information from earlier reports, including draft documents, with little consideration for later revisions or even applicability to the activity in question! Why else would a discussion of the fire-response capabilities at ORNL (inaccurately said to be provided by the Oak Ridge City Fire Department) appear in the ED-3 EA?

It turns out that NEPA document preparation is one more area where DOE has decided it can save money by contracting work out to the low bidder. In taking this approach, DOE has decided against doing these documents in house using the resources of ORNL or another national laboratory with similar qualifications. When cost becomes the primary concern, it is too easy to allow the quality of the product to suffer. In this case, the low-bid contractor is producing documents with poor quality control, and DOE has not provided adequate management to rectify the situation.

Before becoming LOC's Executive Director, I worked in the environmental consulting field. I know this routine–low-cost jobs are assigned to entry-level or low-ranking employees who often lack the background or writing skills to produce a quality piece of work. These employees are then given a limited amount of time to churn out their "deliverable"–their work product. Too often the result is substandard.

DOE may be saving money, but it's a slap in the face to concerned stakeholders. The intangible costs outweigh the monetary savings when the community loses faith in DOE's ability to effectively evaluate and communicate its decisions.

Nickel recycling vs. coal ash recycling

By James S. Johnson, Jr., Ph.D.

Recycling of nickel from the gaseous diffusion process is on hold, in part because of concerns raised about residual radioactivity that would remain after decontamination.

The Tennessee Department of Environment and Conservation has evaluated the process and issued a permit to Manufacturing Sciences Corporation (MSC). The permit allows release of nickel decontaminated to a level, averaged over a shipment, of no more than 3 disintegrations per second per gram of nickel from technetium-99, and 0.6 from uranium. These limits are considered protective of health and consistent with existing regulations here and abroad.

However, the Department of Energy has suspended recycling activities and has instituted a task force in Washington to review this and related matters. Because sale of the recycled nickel is planned to defray a large fraction of the cost of remediation of old gaseous-diffusion facilities at K-25 and return of the area to private-sector industrial use, the matter is of considerable interest to the Oak Ridge community.

It seems worthwhile to make comparisons with other operations not favored with such attention. Babb International plans to build a plant near the Bull Run Steam Plant to make aerated concrete blocks from fly ash. If the fly ash contains the average amount of natural uranium and thorium, there will be about 2.2 disintegrations/sec per gram of the product. This may be compared with the 3.6 disintegrations/sec per gram permitted for the nickel. The actual unit activity of the released nickel may, in fact, be lower. MSC reports that its pilot results attained an average of 1.8 disintegrations/sec per gram from technetium, below the allowed value of 3.

There appears to be a disparity between the level of concern over release of radioactivity to the public sector in the form of nickel and of concrete blocks. When comparing the uses of these materials, keep in mind that the nickel is diluted twenty-fold when alloyed to make stainless steel, while concrete blocks may be used to construct houses, office buildings, and public facilities.

The LOC Board of Directors has written to Energy Secretary Bill Richardson to express concern about the recent DOE decision to curtail commercial recycling of metals with volumetric residual radioactivity. The letter states in part "the moratorium on release of this material will inevitably delay the cleanup and industrial reuse of these buildings."

LOC welcomes new CAP members

The LOC welcomes three new CAP members in 2000:

Bill Rhyne is a consultant with specialization in safety and risk of nuclear/chemical process systems and materials transportation. He consults for an Oak Ridge firm on projects across the U.S. Bill has been impressed with the CAP's nature and level of activity and wants to make a contribution to our efforts to promote responsible cleanup of the Oak Ridge Reservation.
Al Skyberg is an Oak Ridge resident and is retired from a DOE contractor. He has a background in health physics and mechanics, and extensive experience in heavy and light construction. Al's primary interest is in cleaning up recreational waters, since he teaches water safety with the Coast Guard.
Terry Weaver is a former member of the Oak Ridge Site Specific Advisory Board and a former Anderson County Commissioner. He has a scientific background with experience in environmental issues, health and safety, and waste management. He currently owns a business in Oak Ridge. Terry brings unique political and scientific insights to the issues the CAP considers.

We also bid farewell to departing CAP members Gerald Bryant and Ken Greer with thanks for their interest and contributions.

The CAP continues to accept applications for membership. No technical expertise is required, only an interest in making a positive contribution to your community. For an application or more information, call the LOC office in Oak Ridge at (865) 483-1333.

Hot Flashes

Sampling eases concerns about contamination spread

Sediment and substrate being disturbed by construction of the new Highway 58 bridge in Roane County have no significant radiological contamination from cesium-137, according to a TDEC investigation. The agency's DOE Oversight Division responded to recent concerns in investigating construction practices for the bridge, which spans the Clinch River. Cesium-137 is the primary contaminant of concern historically released from the ORR via White Oak Creek. TDEC sampled two areas of spoil material removed from the river, as well as a water sample with suspended sediment. A copy of the two-page report is available from the LOC office.

Delays in BCV ROD raise concerns about delays

DOE believed it had jumped through all the necessary regulatory hoops to create an acceptable interim Record of Decision (ROD) for Bear Creek Valley (BCV). EPA, however, refused at the last minute to sign the document. Delays associated with gathering additional documentation sought by EPA are having a ripple effect, causing delays in milestones associated with remediation of the Boneyard/Burnyard and groundwater pathways from the S-3 Ponds. This situation may also delay construction of the on-site disposal cell, which could delay cleanup activities on other areas of the ORR. By the way, TDEC's DOE Oversight Division found the ROD acceptable and signed it, fully expecting EPA to do the same.

Monoliths on the road to NTS

Oak Ridge has begun shipping concrete monoliths of low-level waste to the Nevada Test Site, according to a report from DOE's team leader for waste management. Clayton Gist reported at the CAP's May 9 meeting that Oak Ridge began shipping the monoliths on April 11 at a rate of about two per week. By the end of this year's shipping campaign in early July, Clayton hopes to have shipped 60 monoliths, three times more than originally planned. Over the past three years, the LOC has actively promoted the opening of NTS to Oak Ridge's waste. Clayton assured us that our letters and networking efforts were a significant contribution to achieving this goal.

Did you know ... ?

The solid wastes (ash) that the TSCA incinerator produces from burning non-Oak Ridge wastes are returned to the shipper or to a generator-approved landfill. Each task requires the approval of the state of Tennessee.
With modern instruments and analytical technology, very small amounts of radioactivity and other pollutants can be detected. Just because it can be measured does not mean it is harmful.
Under Federal law, the U.S. government is forever responsible for cleanup of the Oak Ridge Reservation, even if the land passes to private ownership.

Alphabet Soup

(Initials and acronyms to make this newsletter and other DOE-related documents easier to read)

CAP = Citizens' Advisory Panel
CROET = Community Reuse Organization of East Tennessee
DOE = Department of Energy
EA = Environmental Assessment
EIS = Environmental Impact Statement
EPA = Environmental Protection Agency
LOC = Oak Ridge Reservation Local Oversight Committee, Inc.
MSC = Manufacturing Sciences Corp.
NTS = Nevada Test Site
ORNL = Oak Ridge National Laboratory
ORO = DOE Oak Ridge Operations
ORR = Oak Ridge Reservation
ROD = Record of Decision
TDEC = Tennessee Department of Environment and Conservation

May 2000

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