July 12, 2001

Asst. Secretary Carolyn Huntoon

U.S. Department of Energy

Office of Environmental Management

1000 Independence Ave., SW

Washington, DC 20585

Dear Asst. Secretary Huntoon,

In reference to the Department of Energy's Notice of Intent to Prepare a Programmatic Environmental Impact Statement on the Disposition of Scrap Metals, as published in today's Federal Register, we would like to issue a formal request for an extension to the scoping period in which public comments will be accepted. We urge you to extend this deadline to at least December 10, 2001.

The Department was instructed on January 19, 2001 by then-Secretary Richardson that this Notice of Intent should be published "within 60 days." Concerned stakeholders who were interested in this issue may have come to the conclusion that it had faded from the Department's priorities under the new Administration, since that 60-day time allotment has passed nearly three times. Certainly we are not suggesting that the process be rushed. Considering the seriousness of the issue, it is understandable that a great deal of time and coordinated planning were needed in developing this Notice of Intent for the PEIS, and this is why we ask that you extend the same consideration to the commenting public.

Given the national importance of an EIS that could eventually allow "unrestricted release of scrap metals from DOE radiological areas and scrap metals outside radiological areas that may have residual surface radioactivity" or permit radioactively contaminated metals to be placed in sanitary landfills, we feel that the public deserves more than two months to further study the issue and develop thorough comments. Your own professional staff, which in all likelihood has more time and resources to commit to this issue, was given nearly seven months to prepare this Notice. To allow the public less than two months to comment, especially during the summer months when schedules are irregular, diminishes the potential for meaningful public participation.

Further, the Notice announces that six public meetings that will be held nationally, beginning in less than three weeks. This provides even less time for those who plan to participate to study the relevant issues and prepare accordingly.

Considering the enormous impact such a policy could have, public participation must be taken seriously and processes must be conducted with integrity. Unless corrected, the unacceptably short comment period will further erode public confidence in the Department's handling of the dangerous materials of our nation's nuclear legacy.

Sincerely,

Wenonah Hauter

Director,

Public Citizen's Critical Mass Energy & Environment Program

CC: Secretary of Energy Spencer Abraham

Kenneth G. Picha, Jr., Office of Technical Program Integration