A. In the early 1950’s, it was common practice in the United States Air Force to bury radioactive waste. This was merely a reflection of the AEC policy of those times. A technical order (T.O. 00-110A-1) specified procedures to be followed, including identification of the burial site location on appropriate maps and fencing to prevent entry of unauthorized personnel (reference Appendix A). Although a wide range of radioactive materials was buried throughout the Air Force, a majority of the waste volume could be divided into three categories. The first was electron tubes containing small amounts of radioisotopes. These items were used under the terms of a general license issued by the Atomic Energy Commission. The second category was low-level wastes generated in nuclear weapons maintenance operations. The last category wars radioactive self-luminous instrument dials, usually containing radium.
Page 1, paragraph 1
“Although a wide range of radioactive materials was buried throughout the Air Force, a majority of the waste volume could be divided into three categories. The first was electron tubes containing small amounts of radioisotopes. These items were used under the terms of a general license issued by the Atomic Energy Commission. The second category was low-level wastes generated in nuclear weapons maintenance operations. The last category war; radioactive self-luminous instrument dials, usually containing radium.”
Page 2, paragraph 1
Positive Responses – George AFB
nine bases that were former AEC (Atomic Energy Commission) sites.
Page 7, paragraph (f),
separate letters being sent pertaining to sensitive or classified information, as all material in this report is unclassified.
Page 8, paragraph (g)
Recommendation – George AFB
Summary of Positive Responses – George AFB
burial of radioactive waste at sea in 2 locations.
Page 26, section (2)
1. 72° 43” West Longitude: 38° 40” North latitude
2. 123° 6” West Longitude: 37° 40” North latitude.
Technical Order 00-110N-2, “Radioactive Waste Disposal”
Page 28, paragraph 1.
Technical Order 00-110A-1, Land Burial of Radioactive Waste – 25 May 1956
Page 28, paragraph 2.
Burial of Radioactive Waste must be identified in the Base Master Plan and the information provided to the USAF Radioisotope Committee AFLC (SGPR), Wright-Patterson AFB
Page 28, paragraph 3.
nine USAF bases that were former AEC (Atomic Energy Commission) sites
additional information specific to Kirtland AFB
Page 32 to 71
USAF Radioisotope Committee, “Burial of Radioactive Waste in the USAF,” Wright-Patterson AFB, 15 March 1972.
The complete report for George AFB and the separate letters pertaining to sensitive or classified information was requested under FOIA.
EPA’s analysis of the report(s)
Burial of Radioactive Waste in the USAF (1972 and revisions).
220.127.116.11 Lost AEC Records (this is a large PDF file 18.5mb)
Another recent example of the failure of records to maintain knowledge of waste burial operations pertains to low-level nuclear waste buried on U.S. Air Force controlled land under the authority and purview of the AEC.22 This example in no way establishes or suggests that the sites in question pose an immediate or long-term risk to human health or the environment. Neither is there any implication of negligence on the part of individuals or the federal government. It is merely intended to illustrate the institutional and social processes that can contribute to the success or failure of passive controls.
Most of the sites in question were created in the 1950s, under the auspices of the AEC and in accordance with accepted industry waste disposal standards. The waste materials consisted of radioactive electron tubes, solid and liquid waste from [nuclear] weapons maintenance, radium oxide paint, and medical research wastes. Some burials were made in accordance with specific AEC (now Nuclear Regulatory Commission) licenses.
“Guidance on constructing and maintaining typical sites was given technical order procedures which included identifying site location on appropriate maps and posting and fencing to prevent unauthorized entry. The Air Force switched to disposal at licensed commercial sites in the 1958-1959 time frame and the technical order requirements for burial, and site maintenance requirements was rescinded. Unfortunately, no alternate instructions were provided on maintaining existing sites and a gradual loss of site records ensued. In 1971, the Air Force initiated an effort to find and consolidate existing site records and reestablish site maintenance.”
A review of the facts regarding these sites is as follows:
- Materials were buried under authorized procedures (Air Force and AEC).
- The materials were buried on active duty military reservations that themselves could be considered to be under active control. However, the disposal sites were under passive control.
- The loss of knowledge occurred because of a lapse in institutional reporting and maintenance procedures.
- The lapse was not longer than 12 years (1958-1971).
- The 12-year lapse resulted in the loss of many radioactive waste burial sites. Many are still unaccounted for in 1994.
The following three scenarios could account for the reported losses:
- The facilities at the time of burial did not comply with the technical directive, therefore no location records exist.
- Interviews with base personnel resulted in an assertion of a burial site but there is no location information. These sites are then reported as lost. The sites may or may not exist.
- The facilities did comply, but when active maintenance was lost the site fence and placards were destroyed and the historical records, if any, were not sufficient to establish a location.
22) The information presented here is taken from a document entitled Burial of Radioactive Waste in the USAF (USA72 and revisions).
Criteria for the Certification and Re-Certification of the Waste Isolation Pilot Plant’s Compliance With the 40 CFR Part 191 Disposal Regulations: Background Information Document for 40 CFR Part 194, 1996, EPA doc# 402R96002
PDF pages 431 – 433 or Document page 12-59 to 12-61