November 2009  




In December we’ll know whether the Department of Energy will pull the plug on the Yucca Mountain license application.



Yucca Mountain Slip Sliding Away?

Slip slidin' away

Slip slidin' away

You know the nearer your destination

The more you're slip slidin' away.

Like the Paul Simon song, the Yucca Mountain repository is slip sliding away.  The start up date was first 1998, then 2010, then 2025, and now apparently never.  Unless Congress overturns the projected 2011 Department of Energy (DOE) budget, it calls for $46 million to phase out the project – half for archiving the data and half for site remediation and worker transition. 

 According to the proposed budget, which has not yet been approved by Secretary Chu and the Office of Management and Budget, “All license defense activities will be terminated in December 2009.”  (Energy Daily, November 9, 2009)  In December of this year, the DOE must file papers before the Nuclear Regulatory Commission regarding the proposed repository.  This will be a true indicator of DOE’s intentions.  If DOE does not respond, we’ll know the handwriting is on the wall.  Perhaps, as a return on investment, Disney could turn Yucca Mountain into a theme park, using the tunnels and tracks as a haunted house ride.

 But if Yucca Mountain does not proceed, then what?  Secretary Chu is in the process of selecting members for a blue ribbon panel to identify waste disposal alternatives.  At the present time, utilities across the country are storing highly radioactive nuclear fuel under water in fuel pools and in dry storage casks at reactor sites.  Perhaps these casks will be consolidated at regional storage locations.  Or perhaps the panel will suggest reprocessing, chemically separating the uranium, plutonium and fission products.  Like France, the fission products would be converted into glass logs, waiting for some future repository home.  The first commercial reprocessing business in the United States, by Nuclear Fuel Services at West Valley, New York, was a financial and environmental disaster, but hope springs eternal among nuclear aficionados.

 Kudos for the demise of Yucca Mountain go to Senator Harry Reid and President Obama, satisfying a promise he made during the Presidential campaign.  And kudos go to the many public interest groups, such as NIRS, and Nevada State officials and consultants, such as Bob Loux, Joe Strolin and Bob Halstead, all of whom have been in this battle seemingly forever.  Since 1986, Dr. Marvin Resnikoff has been working with the State of Nevada on transportation issues.


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How will very radioactive “low-level” waste be managed if there is no deep underground repository?








Waste Confidence and “Low-Level Waste”

What do we mean by confidence?  Wikipedia describes confidence as “a state of being certain either that a hypothesis or prediction is correct or that a chosen course of action is the best or most effective.”  In contrast, unmerited confidence--believing something or someone is capable or correct when they are not, is described as “arrogance” or hubris.

 What then are we to make of the findings by the Nuclear Regulatory Commission (NRC) in their Waste Confidence proceeding.  Following five years of hearings and reflection, the NRC Commissioners found in 1984 that “one or more mined geologic repositories for commercial high-level waste and spent nuclear fuel will be available by the years 2007 – 2009.”  Since Yucca Mountain will not operate by the year 2009 and probably never, is this unmerited confidence, arrogance?

 Now that the Commissioners missed the mark in 1984 and again in 1990, what confidence do we have that the Commissioners will get it right this time?  According to the Federal Register of October 9, 2009, the Commission will institute a new Waste Confidence proceeding? What confidence do we have in the predictions of the Commissioners?  And what does this have to do with low-level waste, since the waste repository is for high-level waste and spent nuclear fuel?  Low-level waste is defined as waste that is not high-level waste.

 Low-level waste is buried in landfills.  NIRS and other organizations have raised the issue at new reactor licensing proceedings, that even low-level waste has no home.  But there is a category of low-level waste, called greater than class C low-level waste, that is not destined for landfills.  This greater than class C waste comprises reactor internals that have become extremely radioactive over the 30-year or more operating life of a nuclear reactor.  Prodigious quantities of niobium-94, for example, are present in reactor internals; Nb-94 has a 20,000 year half-life and emits gamma rays.  Greater than class C waste is presently stored in dry storage casks at reactors, just like spent nuclear fuel. According to the NRC (10CFR61.55), this waste “is not generally acceptable for near-surface disposal.” Well if greater than class C waste is not going to a near surface landfill, and there is no deep underground repository, like Yucca Mountain, then what?

 The truth is, even if Yucca Mountain were licensed to hold 70,000 metric tons of high-level waste, greater than class C low-level waste is not part of the present license application.  Only if Congress approved the expansion of Yucca Mountain, and the proposed license were amended, with a new license proceedings, would greater than class C low-level waste finally have a home.


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Will the water drawn from the Rio Grande for

Santa Fe be contaminated with radioactivity?







Los Alamos Waste – You Can’t Sweep It Under the Rug or a Concrete Slab

With Santa Fe County’s plans to obtain additional drinking water from the Rio Grande River, there is renewed concern about the levels of radioactive and toxic chemical concentrations in the river.  The project, called the Buckman Direct Diversion Project, would divert Rio Grande waters to complement underground wells and a reservoir presently in use.  The contamination in the river arises from surface and ground waters from Los Alamos National Laboratory (LANL).  The lab originated in 1943 as one of the Manhattan Project locations established for the development of the atomic bomb.  Originally, the Laboratory consisted of an array of activities relating to plutonium work and weapon component fabrication, as well as weapon testing sites.  Since World War II the Laboratory has continued to serve as a weapons development location, but has also been used for other nuclear work such as nuclear reactor research, biophysics, and radiobiology.  Since the beginning of its operations LANL has disposed of millions of gallons of radioactive and hazardous waste throughout the laboratory grounds and in the canyons that surround the laboratory.  This report summarizes the available information about the radioactive waste disposal history at LANL and assesses the waste inventories of various on- and off-site LANL disposal areas.

Local Geology

Los Alamos and its neighboring areas are located on the mesas and in the canyons of the Pajarito Plateau, which slopes east toward the Rio Grande.  Some of the major canyons of concern, addressed in this paper because of their uses as waste release sites, include the Acid Canyon, Pueblo Canyon, Los Alamos Canyon, Sandia Canyon, Mortandad Canyon and Water Canyon (See Figure 1, p.1 and Section 5 p.49).  In addition to their connection between the top of the plateau and the Rio Grande River, some of the canyons are covered with alluvial deposits, which are unsaturated and have the capacity to absorb large volumes of liquid to the subsurface water table.  This geology allows the possibility that the waste released on top of the plateau has or will descend to the river through streams, subsurface water movement, and sediment erosion.

Disposal of Radionuclides

The waste discharge at LANL began in 1944 during the development of the atomic bomb.  Due to time pressures, secrecy of the project, and general lack of knowledge at the time about the dangers of radioactive materials, the laboratory took poor precautions in its disposal of radioactive and other hazardous wastes during its early years of operations.  Initially, the waste, in the form of liquids, drums and cardboard boxes, was released into the canyons or deposited into unlined pits completely untreated; poor records were maintained about the volumes and activities of these releases.  By the 1960s, the waste disposal practices significantly improved and better records were kept. 

 In order to reconstruct the inventories of radionuclides present at Los Alamos, it is necessary to assess all potential contamination sources including officially designated waste disposal sites, canyons into which liquid waste was released, major accidents that have occurred throughout the years, testing and firing sites, and air particulate releases from vents and stacks. 

The Laboratory is divided into 74 sections, referred to as Technical Areas (Figure 2, p.2).  Fairly complete information exists about the operations of each site, which allows for identifying the specific locations of firing sites and radioactive hazard buildings like waste treatment plants, plutonium processing labs, and nuclear reactors.  Most of the waste disposed of at LANL is buried at 24 officially designated locations, Material Disposal Areas, situated at selected technical areas.  These MDAs range in size, in the type and amount of radioactive waste deposited, and in their potential environmental hazard.  Most MDAs hold solid waste, but some contain barrels with liquids and/or absorption beds, although LANL disposed of the majority of liquid waste into the aforementioned canyons.  In the earlier years the waste disposal practices were crude.  Liquid waste was not treated (Figure 36, p.57) and the solid waste was deposited into unlined pits and packaged in plastic bags or in cardboard boxes sealed with masking tape (Figure 27, p. 39). As practices improved, LANL began treating the liquid waste and sometimes solidifying it with cement.  Likewise, some of the disposal shafts were lined with 12 inches of concrete (such as at MDA C) or covered with concrete caps (such as at MDA H).  This report compiles the available information about the waste disposed of at each Material Disposal Area and into the three canyons, including any recent soil and water sampling results.  Some of the sites with the highest deposits of radioactive contaminants include MDA’s C, G, and H with respective inventories of up to 49,679 curies, 1,383,700 curies, and 391 curies.  Routine sampling of soil and water is regularly performed and radionuclide contamination above background levels is often found at the burial sites (e.g. TA-21).

Little information is available regarding the airborne radionuclide releases from LANL, in the early days of LANL operation.  Some of the point sources would include plutonium from Pu-processing buildings, gaseous fission products from reactors, and radioactive lanthanum tests.  Much of the early equipment and plutonium-processing procedures were crude by modern-day standards.  Hundreds of stacks throughout the laboratory released unfiltered gaseous waste directly from plutonium-processing hoods.  The LAHDRA Project Team has developed a system of priority indices and determined that between 1944 and 1966, plutonium was the most significant contaminant released.  LAHDRA estimated that the total amount of plutonium released by LANL throughout its history, even with the improved filtering systems in later years, exceeded 170 curies.  Airborne radionuclides have the potential to settle on the ground, depending on meteorological conditions of the area and size of the particles, and can present similar dangers as disposed of solid and liquid waste.


We advise ChemRisk and AMEC to thoroughly identify the original and current contaminant inventories within the LANL site and the neighboring areas.  It is essential to identify and model the geological/hydrological formations of the Pajarito Plateau and its surrounding canyons in order to most accurately assess LANL-origin contaminant movement and potential risks to the residents of Santa Fe County.  Finally, we recommend designing an environmental monitoring schedule for the disposal areas to monitor future contaminant mobilization and migration, and developing criteria when emergency measures should be taken.

 You can access the full report by clicking the following link:   LANL Waste Disposal Inventory 11.18.09.pdf


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 Like magic, Ashland Oil waves a wand

and waste is gone.








NORM Waste Disposal in Kentucky

Now You See It, Now You Don’t

It’s magic! It’s amazing what a name means.  Change a waste disposal facility into a waste storage facility and Voila!  Waste gone!

 The NORM waste facility, called by Ashland Oil contractors, the Martha Oil Field Storage Cell, holds oil field waste from the region around Martha, Kentucky.  The contaminated earth in the “temporary” landfill is from waste in oil fields.  Drilling produces radioactive and toxic chemical water that was dumped into unlined pits.  The contaminated earth was then centrally located in the Martha Oil Field storage cell, near Martha, Kentucky.  Now what?

 A report by Auxier & Associates and funded by Ashland Oil purports to show that the waste is safe where it sits.  The supposed safety arises from two sleight-of-hands.  Auxier shows that the facility meets all applicable State of Kentucky regulations.  E.g., the total effective dose to a critical group is less than 25 millirems a year (mrem/yr).  To do that Auxier uses the Department of Energy software, RESRAD-OFFSITE.  That is, the dose due to someone residing off the property is less than 25 millirems per year.  So Auxier does not consider a person residing on the waste facility property.

 And second, Auxier conveniently omits a Kentucky regulation about institutional control.  According to the regulation (902 KARE 100:022 Section 27(2)), “Institutional controls may not be relied upon for more than 100 years following transfer of control of the disposal site to the owner.”  So no fence.  No guards.  Maybe a little note in the title.

 If a person lived on the “waste storage cell,” the radiation dose could be as high as 250 mrem per year to an adult, and 600 mrem a year for a 10-year old child, considerably higher than the 25 mrem/yr the regulatory max for a disposal facility.  Most of this dose comes from growing vegetables, fruits and grains in radium-contaminated earth.  Eat your vegetables, dear; it’s good for you.  And since radium-226 has a half-life of 1600 years, it will be around essentially forever.

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The reef runway at Honolulu International Airport.  Under Paina Hawaii’s plan, one million curies of cobalt-60 in a food irradiator would sit between two runways.





Irradiated Papayas at the Honolulu Airport

The last we left you Paina Hawaii proposed irradiating papayas with one million curies of cobalt-60 between two runways of the Honolulu International Airport.  The likelihood of an air crash into the irradiator was on the order of one in a thousand per year.  While airplanes could bring down the World Trade Center, the NRC staff remained confident the irradiator could withstand an air crash.  Well, hold your papayas!  The Nuclear Regulatory Commission Hearing Board has decided that the NRC Staff environmental assessment was inadequate.

Earthjustice, on behalf of Concerned Citizens, raised numerous safety issues, that were summarily dismissed by the Hearing Board.  No safety issue passed the Board’s muster.  But several environmental issues raised by Concerned Citizens were not adequately considered by NRC staff and must be evaluated.  So it is back to the drawing board for NRC staff on the issues of alternative sites for the facility and alternative technologies.  These are errors of omission, that is, once satisfactorily repaired, construction can proceed, providing the airport authority leases the property to Paina.  This is a big “if.”  RWMA showed that the risk of an air crash would go down by a factor of 1000 if the site were located 10 miles from the Honolulu airport.  In addition, NRC staff must consider alternative technologies to an irradiator.  One additional issue must be evaluated by NRC staff – the environmental impact of an air crash while transporting one million curies of Co-60 to Hawaii.  Since the type B casks that hold the Co-60 rods are designed to withstand a 30 foot drop and planes fly higher than 30 feet, this should be a no-brainer.  But this is the NRC, so the suspense will be figuring out how the NRC staff wiggle their way out of this one.  Stay tuned.


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Oil production in Louisiana’s territorial seas deposit radium into sediments at concentrations that are unsafe.





Extra! Extra! Read All About It!

Pollution License Granted to Gulf Coast Oil Companies

Louisana oil companies were granted a LPDES permit on October 13th. At no surprise to public interest groups overseeing activities of Gulf Coast oil companies and the agency that regulates them, LDEQ, the companies were given everything they wanted, and the public was not given the time of day. All public interest comments were dismissed. The agency set no radioactivity limits on produced water releases into Louisiana coastal waters. The companies do not have to consider the impact of cumulative releases. It’s the new frontier, the Wild West, for oil companies in Louisiana.

Consider this. 150 additional wells are anticipated to be constructed under the LPDES permit just granted, with no environmental assessment required. Radium-226 has been found to have concentrations as high as 1565 picoCuries per liter, far higher than what the EPA considers a hazardous concentration, 50 pCi/L. Rather than requiring a concentration limit at the source, LDEQ will allow companies to mix contaminated water with sea water, and monitor the concentrations 122 meters from the source.

But monitoring concentrations in sea water does not account for the accumulation of radium in sediments. Like salts, radium-226 has been found to accumulate in seafloor sediments when discharged into seawater. High levels of radium ranging from 182 pCi/g to 533 pCi/g were measured in the top ten centimeters of coastal water sediments in Louisiana. In some locations in coastal Louisiana waters, radium activities from produced waters greater than 5 pCi/g were found up to 500 meters from the discharge point.

The public interest group LEAN has recommended that radiation limits be set and that LDEQ consider the cumulative effect of produced water on aquatic biota. RWMA has researched this issue for LEAN. Send us a note and ask for our white paper. And check out LEAN’s web site,

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Radiation Health Effects Controversy

Equivalent, effective

Maybe it’s defective

Let’s call the whole thing off.

A controversy is brewing between the International Commission on Radiological Protection (ICRP) and Professor David Brenner of Columbia University on the usefulness of the effective dose concept.  Effective dose is essentially what used to be called the whole body radiation dose.  It is the radiation dose that is summed over the dose to individual body organs with factors that weigh the radiation sensitivity of each organ.  It is a single number supposedly proportional to the biological detriment or harm to the body.  Importantly, it is not a function of age or gender.  Brenner would replace the effective dose concept with effective risk.  The ICRP disagrees.  Is this important?  Should you care?

Let’s take this from the top.  What is an equivalent dose?  One starts with Roentgens, the unit of measurement for ionizing radiation, the amount of radiation required to liberate positive and negative charges of one electrostatic unit of charge (esu) in 1 cm³ of dry air at standard temperature and pressure.  In short, a Roentgen relates to the ionization potential in air.  The radiation absorbed dose is the amount of energy absorbed in some material, in units of rads.  But to finally get to human tissue, one uses the unit rem or sievert, which is the absorbed dose in human tissue, and this is the equivalent dose.  In going from absorbed dose to equivalent dose, one distinguishes between the type of radiation.  If alpha radiation (2 protons and 2 neutrons), one multiplies by a factor of 20 to account for the ionization potential of a positive doubly-charged alpha particle.

Moving right along here, the effective dose is the sum of the equivalent dose to each radio-sensitive organ multiplied by a weighting factor.  This is also in units of seiverts or rems.  It is a single number, used by regulatory agencies to limit the radiation dose the public may receive.  But the effective dose may not adequately express the risk since the weight factors do not vary with age or gender.  Brenner instead would replace the concept of effective dose with effective risk.  The radiation risk to each organ would be summed.  This would then take into account the gender and age.

For our work at RWMA on personal injury cases, we take into account the age and gender, and also the commitment period, the time between radiation intake and cancer diagnosis, to arrive at the radiation dose to a particular organ.  We do this for the specific organ that became cancerous, in order to determine the likelihood that radiation caused cancer to that organ.

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RWMA  is a New York  City-based consulting firm established in 1989.  Our expert team of scientists and engineers evaluate the impact of proposed and existent radioactive waste facilities to assist organizations that are faced with nuclear waste management issues.




Radioactive Waste Management Associates

526 West 26th Street, Room 517, New York, NY 10001

Ph. 212-620-0526  Fax 212-620-0518