**\
**![](media/image1.png){width="4.388888888888889in"
height="0.375in"}PROPOSAL FOR ADMINISTRATIVE NO FURTHER ACTION
ENVIRONMENTAL RESTORATION SITE 53, BUILDING 9923 OPERABLE UNIT 1335**\
**\
Prepared by Sandia National Laboratories/New Mexico\
Environmental Restoration Project\
Albuquerque, New Mexico\
Prepared for the U. S. Department of Energy

# 1.0 Introduction 

## 1.1. ER Site Identification Number and Name

Sandia National Laboratories/New Mexico (SNL/NM) is proposing an
administrative no further action (NFA) decision for Environmental
Restoration (ER) Site 53, Building 9923, Operable Unit (OU) 1335. ER
Site 53, formerly included in OU 1298, was identified in the Hazardous
and Solid Waste Amendment (HSWA) Module IV (Ref. 1) of the SNL/NM
Resource Conservation and Recovery Act (RCRA) Hazardous Waste Management
Facility Permit (NM5890110518) (Ref. 2).

## 1.2 SNL/NM Administrative NFA Process

This proposal for a determination of an administrative NFA decision has
been prepared using the criteria presented in Section 4.5.3. of the
SNL/NM Program Implementation Plan (PIP) (Ref. 3). Specifically, this
proposal will \"contain information demonstrating that there are no
releases of hazardous waste (including hazardous constituents) from
solid waste management units (SWMU) at the facility that may pose a
threat to human health or the environment\" \[as proposed in the Code of
Federal Regulations (CFR) Section 40 Part 264.51(a) (2)\] (Ref. 4). The
HSWA Module IV contains the same requirements for an NFA demonstration:

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  Based on the results of the RFI \[RCRA Facility Investigation\] and
  other relevant information, the Permittee may submit an application to
  the Administrative Authority for a Class III permit modification under
  40 CFR 270.42(c); to terminate the RFI/CMS \[corrective measures
  study\] process for a specific unit. This permit modification
  application must contain information demonstrating that there are no
  releases of hazardous waste including hazardous constituents from a
  particular SWMU at the facility that pose threats to human health
  and/or the environment, as well as additional information required in
  40 CFR 270.42(c); (EPA August 1993).

  -----------------------------------------------------------------------

In requesting an administrative NFA decision for ER Site 53, Building
9923, this proposal is using existing administrative/archival
information to satisfy the permit requirements. This unit is eligible
for an administrative NFA proposal based on one or more of the following
criteria taken from the RCRA Facility Assessment (RFA) Guidance (Ref.
5):

Criterion A: The unit has never contained constituents of concern

Criterion B: The unit has design and/or operating characteristics that
effectively prevent releases to the environment

Criterion C: The unit clearly has not released hazardous waste or
constituents into the environment

Specifically, ER Site 53 is being proposed for an administrative NFA
decision because the SWMU clearly has not released radioactive or
hazardous waste or constituents into the environment (Criterion C).

SNL/NM occupies 2,829 acres of land owned by the Department of Energy
(DOE) , with an additional 14,920 acres of land provided by land-use
permits with Kirtland Air Force Base (KAFB), the United States Forest
Service (USFS), the State of New Mexico, and the Isleta Indian
Reservation. SNL/NM has been involved in nuclear weapons research,
component development, assembly, testing, and other nuclear activities
since 1945.

Site 53 (Building 9923) is a small concrete earth-covered storage igloo
located east of SNL/NM Technical Area III, near building 9920, (see
Figure 1). The terrain is flat with some vegetation, primarily sage and
tumbleweeds. The shallow subsurface geology is comprised of alluvial
sediments, clay to gravel/cobble size. Depth to ground water at the
nearby Chemical Waste Landfill wells has been measured at around 500
feet.

# 2.0 History of the SWMU

## 2.1 Sources of Supporting Information

In preparing to request an administrative NFA decision for ER Site 53, a
background study was conducted to collect available and relevant site
information. Background information sources included existing records
and reports of site activity. In addition interviews were conducted with
SNL/NM staff and contractors familiar with site operational history. The
study was completely documented and has provided traceable references
which sustain the integrity of this proposal.

The following information sources, hierarchically listed with respect to
assigned validity were available for use in the evaluation of ER Site
53:

-   One preliminary radiation survey report, including data from
    radiation swipe surveys

-   Two interviews with two ER Site 53 facility personnel

-   Miscellaneous information sources including SNL/NM personnel
    correspondence (memorandums, letters, and notes regarding ER Site
    53)

-   Photographs and field notes from numerous site inspections conducted
    by SNL/NM staff

-   The Comprehensive Environmental Assessment and Response Program
    (CEARP) Phase I Report (Ref. 4) and CEARP records. (Copy contained
    in the SNL Environmental Operations Records Center)

Utilizing this information, a brief history of ER Site 53 and a
discussion of all relevant evidence regarding past waste practices and
releases at the site have been prepared and are presented in this
proposal for an administrative NFA decision.

## 2.2 Previous Audits, Inspections and Findings

The original CEARP information from interviews conducted in 1985 states
that, \"Building 9923 contains some radioactive material from neutron
activation experiments at the Nevada Test Site. Materials are confined
to the building and no environmental release is expected\" (Ref. 3). The
CERCLA finding for this unit was negative for the Federal Facility Site
Discovery and Identification Findings (FFSDIF), the Preliminary
Assessment (PA), and the Preliminary Site Inspection (PSI). Therefore,
no Hazard Ranking System (HRS) or Modified Hazard Ranking System (MHRS)
migration mode scores were calculated.

## 2.3 Historical Operations

This facility is the Shock Wave Studies Laboratory and is operated by
organization 6423.

Building 9923 is a small igloo-shaped storage building at the Shock Wave
Studies Laboratory designed to store explosives. The igloo interior is a
3-feet x 3-feet steel-walled structure with a concrete floor. An earthen
berm with approximate dimensions of 9 x 9 x 6 feet covers the structure
to suppress accidental detonation of the stored explosives (see Figures
1, 2 and 3). The structure is locked so access is restricted. According
to the interviews with individuals responsible for Building 9923,
radioactive materials from neutron activation experiments at the Nevada
Test Site were stored at this unit (Ref 6 and 7). It was not known when
the material was originally stored there, but is believed to have been
stored for at least six years, from 1985-1991. The interviewees
indicated the materials were properly contained, labelled, and stored,
and no release to the environment has occurred from this unit (Refs. 6
and 7).

The radioactive material was completely removed in February of 1991 and
follow-up swipe samples were collected by the SNL Radiation Protection
Operations (RPO) group to test for contamination of the building (Ref.
6). Results from this swipe survey are discussed in Section 3.4.

# 3.0 Evaluation of Relevant Evidence

## 3.1 Unit Characteristics

Building 9923 is a small storage bunker designed to contain explosives.
The bunker interior is lined with corrugated steel pipe and a concrete
floor. The interior is about 3 x 3 x 3 feet and the exterior is covered
by an earthen berm.

## 3.2 Operating Practices

Although it has been documented that radioactive materials were
contained in Building 9923 there was never any documentation of a
release (Refs. 6, 7 and 8). Based on available information, the
radioactive materials were properly contained and labelled. No
environmental release ever occurred at this facility.

## 3.3 Presence or Absence of Visual Evidence

nspection of the igloo during another follow-up sequence of swipe survey
conducted by SNL/RPO in August 1994 indicated that there was no visual
evidence of a release. There were no visible free liquids, solids, or
stains which could have leaked from the radiation waste container. This
is supported by photographic documentation of the interior of the igloo,
Building 9923 (see Figures 2, 3 and 4).

## 3.4 Results of Previous Sampling/ Surveys

After the radioactive materials were removed from Building 9923 in 1991,
follow-up swipe samples were collected by the RPO group to test for
contamination of the interior of the building. The building is presently
empty. According to the interviewees, no radiation contamination was
detected in this survey (Ref. 1), however, the report from this survey
could not be obtained.

A second radiation survey was conducted in the igloo in August 1994, to
verify the interview statements regarding the 1991 swipe survey. The
igloo interior was screened for alpha radiation and beta-gamma radiation
with a HP-260 pancake probe. Also, eight swipe samples were collected
from the floor and interior walls of the structure and analyzed for
alpha and beta radiation. In the surface screening survey, all surfaces
were found to be within the contamination limits prescribed by the DOE
Radiological Control Manual (Ref. 9). Alpha and beta radiation in the
swipe samples were below minimal detectable activities (MDA). No
radiation contamination was detected in this second survey (See
Attachment 1) (Ref. 10).

## 3.5 Assessment of Gaps in Information

Although there was no documentation of a release of radioactive
materials during storage at Building 9923, recent swipe surveys taken in
August 1994 verify that no release occurred.

## 3.6 Rationale for Pursuing an Administrative NFA Decision

Based on interviews with personnel involved with the facility, visual
photographic evidence, the review of analytical results of swipe samples
collected, and radiation screening of the unit, it is evident that:

-   According to interviewees, the neutron activation experiment
    materials that were stored in Building 9923 were properly
    containerized, labelled and stored.

-   No release of radioactivity to the environment has occurred at this
    unit as determined from two radiation swipe surveys of the site
    which were conducted in 1991 and 1994.

Therefore Criterion C for an NFA administrative proposal applies: The
unit clearly has not released (radioactive) or hazardous waste or
constituents into the environment.

# 4.0 Conclusion

Based on the evidence cited above, no potential remains for a release of
hazardous waste (including hazardous constituents) which may pose a
threat to human health or the environment. Therefore ER Site 53 is
recommended for an NFA determination.

# 5.0 References

U.S. Environmental Protection Agency (EPA), August 1993, Module IV of
RCRA Permit No. NM 5890110518, EPA Region 6, issued to Sandia National
Laboratories, Albuquerque, New Mexico.

U.S. Environmental Protection Agency (EPA), August 1992, Hazardous Waste
Management Facility Permit No. NM 5890110518, EPA Region IV, issued to
Sandia National Laboratories, Albuquerque, New Mexico.

Sandia National Laboratories/New Mexico (SNL/NM), February 1994, draft.
\"Program Implementation Plan for Albuquerque Potential Release Sites,\"
Sandia National Laboratories, Albuquerque, New Mexico.

U.S. Environmental Protection Agency (EPA), July 1990. \"Corrective
Action for Solid Waste Management Units (SWMU) at Hazardous Waste
Management Facilities Proposed Rule,\" *Federal Register*, Vol. 55,
Title 40, Parts 264, 265, 270 and 271.

U.S. Environmental Protection Agency (EPA), October 1986, \"RCRA
Facility Assessment Guidance,\" EPA/530-86-053, PB87-107769, Washington
DC.

Gaither, K. Memorandum to ERST Files, \"ER Site 53, Building 9923,\"
October 28, 1991.

Sandia National Laboratories/New Mexico (SNL/NM) Records Center
Reference Number ER/7585/1335/53/INT/85-73

Garcia, D., Memorandum to Cox, W., \"Changes to ER Program Site List,\"
June 24, 1992.

Sandia National Laboratories/New Mexico (SNL/NM), January 1995, *SNL
Radiological Control Manual*, MN 471015, Issue A, Sandia National
Laboratories/New Mexico, Albuquerque, New Mexico.

TA3 Office, Radiation Protection Operations, 7714, Memorandum to Skip
Wrightson, \"Radiological Survey Results, Bldg. 9923,\" August 25, 1994.

U.S. Department of Energy (DOE), September 1987. Draft \"Comprehensive
Environmental Assessment and Response Program, Phase 1: Installation
Assessment Sandia National Laboratories - Albuquerque,\" Department of
Energy, Albuquerque Operations Office, Environment, Safety and Health
Division, Environmental Programs Branch, Albuquerque, New Mexico.

U.S. Environmental Protection Agency (EPA), April 1987. RCRA Facility
Assessment Draft Report, \"Final RCRA Facility Assessment Report of
Solid Waste Management Units at Sandia National Laboratories,
Albuquerque, New Mexico,\" EPA, Washington, DC.

# ATTACHMENT 1 (Not available at this time.)

Radiological Survey Results

Radiological Survey Form

Radiological Survey Map

Low Background Counting System - Smear Analysis

# Figures (Not available at this time.)