EPA’s analysis of the report(s) Burial of Radioactive Waste in the USAF (1972 and revisions).
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in the 1958-1959 time frame and the technical order requirements for burial, and site maintenance requirements was rescinded.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
22.214.171.124 Lost AEC Records (this is a large PDF file 18.5mb)
PDF pages 431 – 433 or Document page 12-59 to 12-61