[ RadSafe ] Fw: Uranium contamination

Dan W McCarn hotgreenchile at gmail.com
Fri Apr 2 19:01:04 CDT 2010


Dear Jerry & Cary:

As you well know, there are regulatory requirement to clean-up to a given
criteria.  There are 3 different "endpoints" for cleanup that can be
identified:

1) Pre-activity baseline;
2) Technical feasibility limit;
3) Risk-based limits.

In any proposal for cleanup, there can be several proposed options including
a no-action option.  In the past, I have successfully argued to regulators
that cleanup (of a chlorinated solvent spill) was:

1) Technically infeasible; 
2) Would create more dispersion of the chemicals; 
3) That there was a ongoing, demonstrable process of natural attenuation;
4) That the current, undisturbed risk was minimal.  

Action to "clean-up" a site may, in fact, create more problems
environmentally than it solves.  No-action option may be argued
successfully.

I have also argued successfully to close and remediate existing LLRW waste
facilities outside the USA as an IAEA expert as well as to include multiple
options for proposed actions involving uranium mill tailings / mine
decommissioning, again outside of the USA.

The public has every right to understand these issues through the EIS or EA
process during which the "real benefits to public health" can be carefully
discussed.  In my opinion, it is the lack of knowledge and the resulting
fear that causes more problems than any other cause.

Closure of any facility involving potential uranium contamination (or any
other Nuclear Fuel Cycle process waste) to me is unthinkable without a
detailed environmental assessment of that facility. Only then can a
"no-action option" be considered based on risk and technical feasibility.

Dan ii

--
Dan W McCarn, Geologist
2867 A Fuego Sagrado
Santa Fe, NM 87505
+1-505-310-3922 (Mobile - New Mexico)
HotGreenChile at gmail.com (Private email)

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Jerry Cohen
Sent: Friday, April 02, 2010 16:51
To: Cary Renquist; Jerry Cohen; radsafe at health.phys.iit.edu
Subject: Re: [ RadSafe ] Fw: Uranium contamination

Cary,
      So--- as I suspected, the cleanup of  uranium contaminated areas is 
just another expensive, taxpayer funded, "feel-good" program, intended to 
give the impression, that the government is somehow protecting the public 
against a genuine threat to health and safety. It might not be so egregious 
if there were not any real problems out there which, if addressed and 
solved, could give some real benefit to public health. It seems to me that 
implementation of large scale conspicuous  clean-up efforts could only 
confirm and aggravate  unfounded fears . Such "feel-good" programs intended 
to  assuage unfounded fears are not only ineffective, but could actually be 
counter-productive
Jerry



----- Original Message ----- 
From: "Cary Renquist" <cary.renquist at ezag.com>
To: "Jerry Cohen" <jjc105 at yahoo.com>; <radsafe at health.phys.iit.edu>
Sent: Wednesday, March 31, 2010 3:50 PM
Subject: Re: [ RadSafe ] Fw: Uranium contamination



Why?
Public perception and politics.
(especially since we are dealing with evil weapons radiation and not benign 
natural or medical radiation)

The driving issue is that there is likely a regulatory requirement to clean 
up this material -- the health and safety decision was made when the 
decommissioning criteria were set (which means that it is probably more of a

political decision that a true health-n-safety one).
I imagine that U was chosen because the DOE has responsibility for sites 
where U is the main contaminant and not other toxic metals... Or it might be

that there isn't a bacteria that can "fix" the other metal species.

Does "technologically enhanced" U concentration in the soil constitute a 
credible threat -- not bloody likely.  There could very well be a geological

formation a few miles down the road that leads to U levels that are far 
higher than the "enhanced" DOE sites, but unfortunately regulatory 
requirements demand that we be good boy scouts and leave our licensed site 
in the same condition that we found it (if not better condition).

It is a bit similar to the fact that as a rad licensee, I need to be very 
careful to monitor what goes out of my facilities and how I transport rad 
material, but I can pick up a family member from the hospital on my way home

and transport 150 mCi+ of I-131 unshielded/labeled/etc, have dose rates 
greater than 2 mR in any one hour outside my house, and release unmonitored 
material through the sewer.  If I dump 150 mCi of I-131 on the bushes 
outside of my licensed facility I'll be in big regulatory trouble -- if my 
family member gets car sick and throws-up 150 mCi on the bushes outside of 
my house, there is no problem.

Cary

---
cary.renquist at ezag.com


-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu 
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Jerry Cohen
Sent: Wednesday, 31 March 2010 14:43
To: radsafe at health.phys.iit.edu
Subject: [ RadSafe ] Fw: Uranium contamination

Uranium is just one of the 92+ elements in soil. Why choose it for such a 
study. Why not lead, cadmium, mercury, etc. I would assume, that for some 
reason, U is considered to be an exceptionally hazerdous material to justify

expenive remediation. I was trying to learn what that reason might be.
Jerry Cohen


----- Forwarded Message ----
From: Jerry Cohen <jjc105 at yahoo.com>
To: Cary Renquist <cary.renquist at ezag.com>; radsafe <radsafe at radlab.nl>
Sent: Fri, March 19, 2010 8:14:02 PM
Subject: Re: [ RadSafe ] Uranium contamination


Does the existence of Uranium contamination in soil constitute a credible 
threat to heath and safety, or is this just another costly federal 
"feel-good" program? If such uranium contamination is really a problem, what

should be done with the millions of tons of uranium in the oceanic coastal 
waters. We even allow children to swim in it.
Jerry Cohen



________________________________
From: Cary Renquist <cary.renquist at ezag.com>
To: radsafe at health.phys.iit.edu
Sent: Fri, March 19, 2010 6:10:01 PM
Subject: [ RadSafe ] Argonne scientists seek natural remediation for 
uranium-rich sites

They are looking to understand and optimize the conditions under which
bacteria can
transform U(IV) <soluble> to U(VI) <insoluble>

Argonne scientists seek natural remediation for uranium-rich sites
Link http://j.mp/b3AHAh


Cary
-- 
Cary.renquist at ezag.com

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