DOE OSTI2018
In 2013, the Office of Management and Budget issued Memorandum 2013-02, clarifying its 'Freeze the Footprint' policy. Memorandum 2013-02 requires that all federal agencies maintain or reduce their total square footage, within each subsequent year, from a FY2012 baseline. Memorandum 2013-02 also requires that total square footage remain constant with respect to the type/intended use of a building. At Los Alamos National Laboratory (LANL), this means that new construction cannot occur without demolition of equivalent (both in type and square footage) building(s). Since 2013, decommissioning and demolition of aging, unused facilities at LANL has increased. In 2016, the TA16-280 building complex was scheduled for demolition. TA16-280 is a former high explosives (HE) processing facility that consists of six buildings connected to each other via weatherproof walkways. It was constructed in the 1950's and has been subsequently used for HE shipping, receiving, and storage. Interviews with radiation protection staff suggest that some of the buildings within the complex may have been used to store depleted uranium metal parts in a non-dispersible form. It is LANL policy to conduct decommissioning surveys for radioactive materials when building history cannot confirm that a structure is radiologically non-impacted. LANL follows the Multi-Agency Radiation Survey and Assessment of Materials and Equipment (MARSAME) process to develop its surveys and clear structures from radiological control. After clearance, a structure may be dispositioned as non-regulated waste, at a significant cost savings compared to regulated disposition pathways such as low-level waste. MARSAME measurements conducted in the 16-280 complex were elevated compared to reference measurements of surrogate materials, and a majority of the survey units failed to pass indistinguishable from background (IFB), which is LANL's unregulated clearance criteria. Further measurements conducted both in situ and in the laboratory indicated the presence of naturally-occurring thorium in several building materials including: poured concrete, the glaze atop ceramic blast tiles, and the porcelain enamel on the exterior of blast-proof ceiling lamps. Other than naturally-occurring thorium, there were no elevated radionuclide concentrations detected in building materials. It should be noted that there was no history of thorium use in the 16-280 complex, and the material in question was in all cases fixed to and within the building materials in question. Except in certain specific cases, such material is exempt from regulation under the Atomic Energy Act of 1954 [3], as amended, and is therefore exempt from regulation under the Nuclear Regulatory Commission, the Department of Energy, and agreement state regulatory frameworks. Despite this regulatory exemption, disposition of material from the 16-280 complex proved to be challenging, principally because local industrial landfills stipulate 'No radioactive material' in their Waste Acceptance Criteria. This disconnect between what is regulated and what is disposable creates a situation where some DOE sites find it easier to disposition property as Low Level Waste in lieu of pursuing a non-regulated disposition pathway. This presentation will explore the specifics of the 16-280 decommissioning project as well as the implications of the release/disposition disconnect for naturally occurring radioactive material and project planning at LANL. (authors)
12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗