BY MAIRE O’NEILL
The results of an assessment conducted by the Department of Energy’s Office of Enterprise Assessments concerning the way Los Alamos National Laboratory handles the transfer of excess real property have been released. The Disposition of Excess Real Property Assessment at the Los Alamos National Laboratory Middle DP Road Site – November 2021 | Department of Energy assessment specifically examined the processes used to convey DOE land on DP Road to Los Alamos County where buried waste related to LANL operations during the Manhattan Project was discovered that had not been identified during land characterization activities.
On February 14, 2020, legacy LANL waste was uncovered in a trench being excavated by a Los Alamos County contractor for new sewer infrastructure on DP Road. A total of four discoveries were made of waste materials on three tracts of land that had been transferred to the County – A-16-a, A-8-a and A-b. The area has become known as the Middle DP Road Site.
Recommendations were made in the assessment that are intended to provide insights for potential improvements at LANL and potentially other DOE sites that conduct activities to disposition excess real property. Recommendations for DOE Headquarters included: revise definitions of real property and personal property that address radiologically contaminated waste; Issue guidance for investigating potential subsurface radioactive contamination (greater than six inches below the surface);
The assessment recommends that NA-LA conduct additional investigation of A-8-b for undiscovered disposal pits in two locations not previously sampled – one between the previously excavated utility trench and the eastern boundary, and the other in the southeast corner. It is also recommended that NA-LA in collaboration with EM-LA conduct a formal root cause analysis on the Middle DP Road events of 2020 and that the results be used to develop a corrective action plan. The results would be shared as lessons learned and operating experience across the DOE complex.
Among the items recommended for causal analysis is the initial response to finding buried waste. The report notes that the Los Alamos County contractor uncovered buried waste items February 14, 2020 and the following day, contacted the Emergency Operations Support Center, which advised him to contact the County’s dispatch center.
Los Alamos Police and Fire Departments responded, treating the discovery as a HAZMAT situation.
“LAFD contacted the EOSC incident response commander, requesting LANL HAZMAT and radiological control technician as consultants. The incident response commander informed LAFD that the DOE radiological assistance program (RAP) team was the appropriate resource, and provided the team’s duty pager number. LAFD surveyed the discovered buried waste and determined that the radiological hazard was not an imminent threat to human health based on low-level gamma exposure rate instrument readings; however, this instrument was not suitable for detecting early Pu, which only emits alpha radiation,” the report states.
It goes on to say that unaware that the samples were radiologically contaminated, LAFD subsequently provided them to LAPD for explosive analysis at the police department.
“After LAPD determined that the samples did not contain explosives, they discarded the samples in a sanitary waste dumpster. The LAC excavation contractor then retrieved the discarded samples from the waste container and returned them to the jobsite,” the report states. “On February 20, 2020, six days after the LAC excavation contractor’s initial notification to the EOSC, NA-LA requested that the RAP team be activated.”
The report notes that complicating factors associated with requesting the RAP assistance included that LAFD did not measure any hazardous levels of radiation emitting from the waste debris and that the event was not on DOE property, thereby requiring the request for RAP assistance to come from LAC.
“…. LAFD and LAPD handled buried waste with unknown fixed radioactive contamination (which is not readily transferred to another object) without controls. Upon notification, two RAP teams and a RAP Federal Team Leader responded…. Over the next several days, the teams surveyed the scene, the excavation contractor’s equipment, LAFD equipment, other personal property, the sanitary waste dumpster at the police station, and the police vehicle used to transport the samples. Samples were also sent to the LANL Health Physics Analytical Laboratory (HPAL). HPAL interpreted the initial data from sample analysis as indicating uranium contamination. However, in subsequent analyses, HPAL determined that the contaminant was actually Pu (an alpha emitter), without the normal daughter product Am-241 (a gamma emitter). This signature is characteristic of early Manhattan Project material produced in low flux reactors (i.e., early Pu). The absence of easily detected gamma radiation makes detection of this early Pu exceptionally difficult with field instruments. No spread of contamination was detected,” the report states.
The assessment recommends that NA-LA “provide awareness training to the LAFD on the survey practices for early Pu and verify that the radiological survey equipment used by LAFD is capable of detecting early Pu contamination and/or other alpha, beta, and gamma emitting radionuclides”.
The assessment recommended that Triad develop a corrective action plan to address land previously conveyed from LANL that the extent of condition report refers to as “potentially elevated risk”. The full document may be reviewed at: Disposition of Excess Real Property Assessment at the Los Alamos National Laboratory Middle DP Road Site – November 2021 | Department of Energy