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RE: Hanford Site cleanup standards [corrected and re-posted]

This comment is also being sent to RISKANAL.



[and is re-posted to correct some typos and because I forgot the signature and disclaimer the first time]



Doug Aitken wrote:

-----Original Message-----

From: Doug Aitken [mailto:daitken@sugar-land.oilfield.slb.com]

Sent: Thursday, August 28, 2003 8:33 AM

To: Dukelow, James S Jr; William V Lipton; Conklin, Al

Cc: BLHamrick@AOL.COM; RuthWeiner@AOL.COM; radsafe@list.vanderbilt.edu

Subject: RE: Hanford Site cleanup standards







>-----Original Message-----

>From:   William V Lipton [mailto:liptonw@dteenergy.com]

>..... What is clear is that to achieve any reasonable cleanup will be 

>expensive.

>To actually return the land to an undegraded condition is probably

>beyond what we can afford.



As a newcomer, the following may well have been covered, and considered. So 

please excuse an amateur entering into this debate....



But a point I have not seen raised is the risk involved in the clean-up 

itself (of any site, to a given "safe" level). I imagine it would be 

possible to do a risk analysis of the cleanup operation itself, based on 

past experience.

And not just the radiological risk, but the overall risk of all cleanup and 

storage operations (personal injuries, vehicular accidents, contamination 

dispersion outside the site, etc.)

Obviously, it is necessary to remove the really bad stuff, but, at some 

point, you get to (very) diminishing returns. And  the risks involved in 

continuing the cleanup will outweigh the benefits, expense notwithstanding.



Somewhat analogous to the choice between removal of hard asbestos 

insulation from a building or sealing it in place. Generally more risk is 

involved in the cleanup than leaving everything as is (with suitable 

sealing and maintenance).



But I guess that the forces that drive these cleanups (greenies, a 

frightened, misinformed, public and, of course, the lawyers......) consider 

the workers who do the cleanup as "expendables" .....





Doug Aitken		Schlumberger Drilling and Measurements QHSE 

Advisor

Phone (Sugarland):   	281 285-8009

Phone (Home office): 	713 797-0919	

Phone (Cell): 		713 562-8585

Principal E-mail: jdaitken@earthlink.net

Schlumberger E-mail: daitken@sugar-land.oilfield.slb.com

Mail: 	300 Schlumberger Drive MD2, Room 111

	Sugar Land, TX 77478



====================



Doug Aitken makes an important point.



Over the past 15-20 years or so, it has been impossible to get out of DOE clear regulatory guidance on the trade-off between public risk reductions from cleanup and worker risk increases due to the same cleanup activities.  The situation may have changed in the last 2-3 years, but I am not aware of any such changes.



For all analyses I have seen, at the actual levels of residual risk to the public, the increase on occupational risk due to cleanup was an order of magnitude of more greater than the reduction in public risk.



Best regards.



Jim Dukelow

Pacific Northwest National Laboratory

Richland, WA

jim.dukelow@pnl.gov



These comments are mine and have not been reviewed and/or approved by my management or by the U.S. Department of Energy.







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