Let’s put it this way: We know that the DOE has operated nuclear power plants at the DOE sites for a very long time, longer in most cases than the commercial facilities. We know that fission product materials were generated and thusly contaminated equipment and materials. This equipment and materials were then either buried on the site where the waste was created or transferred/shipped to other DOE sites for disposal. We also know that over the years the containment material used for this waste was not exactly long lived and therefore potentially infiltrated the land or ground water of the burial site. Several documents related to alpha contamination suggest that “caution should be exercised in performing work where “old/aged” alpha contamination may be present, but inaccessible. As stated above, some examples of such areas include radioactive waste storage buildings containing legacy waste, contamination beneath primary system component heat insulation that may have experienced primary fluid contamination during a fuel defect cycle, pressurizer heater sleeves, and Rx Head CRD Thermo Sleeves. Another potential source of alpha contamination can be equipment from another facility with an unknown history. In these cases, consideration should be given to determining a separate area-specific distribution, assigning a higher Area Level, or assuming the most restrictive nuclide in the mix.” Based on this are we or have we been characterizing DOE land for residual alpha contamination on a routine bases since many of us work in the outer most areas of DOE sites that may have unknown waste burial locations or is it assumed that because it is in the far reaches of these sites it doesn’t exist.
I was trying not to go into this detail but I guess I should have. No I am not writing a book and no I have no further intent with this subject other than opinions and discussion.
This is a little off topic but simular. I worked one site that was not suppose to have any radiological contamination. It was discovered when the site was monitored for demolition and site cleanup. Early attitudes toward uranium was that if it did not fall on your head it was not that hazardous it was a low specific activity natural material. Equipment contaminated with uranium in the late 40s early 50s had been shipped to this site resulting in a radiological cleanup. I worked another site that had no enriched uranium on site before the NORM regulations and only used alpha instruments for surveys. When beta-gamma instruments where introduced many carpets, fabric chairs, and tools from tool boxes were confiscated from the clean side of the facility. Legacy Manhattan Project facilities and other facilities built before today's regulatory environment may pose some discovery issues whether that be alpha contaminated material or other hazardous material (gives me a paycheck). You can include asbestos, mercury, lead and a host of other materials that were used liberally prior to RCRA regulations in 1975, that describes almost all of the DOE facilities being demolished/remediatied. Radiological/hazardous material handling has changed drastically in the last forty years I have worked in the industry and much more so since the early part of the last century which has left legacy waste to be disposed of that was generated in a much different regulatory and social environment.
Remediation and closeouts already accomplished are just that - accomplished.
To reopen investigation and remediation based on contemporary standards, guidelines and regulations means asking people to reopen their wallets for something they have already been assured was "done".
It also opens the door to an avalanche of torts, compensations, et al.
The vast majority of previous remediation and closeout accomplishments are defensible within the parameters of current dose based risk assessment models. Properly backfitting the data into a defensible model can be a challenge, but that's why we get paid good coin to do it.
The contemporary MARSSIM model works well enough, at the end of the day comprehensive Historical Site Assessment is the answer SCMasterchef is looking for.
As to Marlin's post, it is a good illustration that regulations, thresholds, standards, technology and implementation is constantly evolving. There is no right and wrong in these endeavours, only legal and illegal. You can evolve with it or be unemployed, your choice.
ETD,...
