Page 359 - Beyond Decommissioning

Case studies of nuclear redevelopment 335

sampling and laboratory support personnel were not immediately advised of this
change in RCRA status for waste generated at the site. Failure to communicate the
change in RCRA status in a timely manner resulted in the improper handling of poten-
tial U- and F-listed waste.
Analysis: A management failure to communicate, in a timely manner, a substantial
change in regulatory status to all impacted personnel has been identified as the pri-
mary cause of this event.
Lessons learned: Changes in the regulatory status of environmentally regulated
areas (RCRA, CERCLA, etc.) in and around US Department of Energy (DOE) facil-
ities should be communicated to all personnel who direct or perform work in the sub-
ject areas. Failure to keep personnel updated on current regulatory status could result
in violations of procedural and/or regulatory requirements.

7.14.8 Redevelopment and reuse complicated by drains legacy,
United Kingdom (International Atomic Energy Agency,
2011)
Problem encountered: A large nuclear research site with hundreds of buildings used a
network of drains, developed over decades, to link the buildings to a central liquid
effluent treatment plant. The drains included:
– pipes dissipating wastewater into the soil (soakaways);
– industrial effluent systems, which were designated as radiologically inactive;
– old active drains with no secondary barriers;
– modern active drains with secondary barriers; and
– rainwater drains.
Problems included:
– overlapping of different types of drains and delay tanks, which had been installed with no
decommissioning of old systems;
– drains collapsed or leaking;
– inactive drains inadvertently used for active effluents;
– drains that were not recorded on site drawings;
– some drains had been decommissioned but no records were made of their location, contam-
ination found, etc.;
– some drains had been grouted in situ with insufficient records; and
– rainwater was penetrating into drains creating unneeded effluent.

Solution found: A program of drains decommissioning was established to allow site
redevelopment. The remaining buildings requiring drainage were segregated and had
dedicated systems. The remaining network of drains was decommissioned, which
included the following activities:
– identification and mapping;
– use of a geographical information system to record and map progress;
– flushing of drains;
– contamination monitoring using a pipe crawling robot;