12    AIR MODELING AS AN ALTERNATIVE TO
SAMPLING FOR LOW-LEVEL RADIOACTIVE
AIRBORNE RELEASES
Michelle Morgenstern, Project Engineer
ERM Program Management Company
Los Alamos, New Mexico 87544
Kirby Hueske, Toxicologist
Texas Natural Resources Conservation Commission
Austin, Texas 78731
INTRODUCTION
The Environmental Restoration Program for Department of Energy (DOE) nuclear weapons
complex facilities faces challenges ranging from well-defined cleanups of specific contaminated
sites to broader questions of the effects on the environment and human health of forty years of
laboratory operations. Efforts in the latter category were accelerated by the promulgation of the
National Environmental Policy Act (NEPA) of 1970, the Resource Conservation and Recovery
Act (RCRA) of 1976, the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) of 1980, and the Superfund Amendments and Reauthorization Act (SARA) of
1986 which require the DOE nuclear weapon complex facilities to comply with the same standards applied to industry. The DOE responded to the new regulatory requirements by the implementation of the Comprehensive Environmental Assessment and Response Program (CEARP),
designed to bring Los Alamos National Laboratory (LANL) into compliance with RCRA and
CERCLA.1^ A particularly striking example of the effect of these regulatory requirements is the
new scrutiny focused on airborne radioactive releases from DOE laboratories and the cumulative
effect of past releases. This paper describes our efforts to assess the effect of these airborne releases at one DOE laboratory using air modeling based on historical data.
Among the facilities affected by these developments is Los Alamos National Laboratory in
New Mexico. LANL is located on several mesas above the Rio Grande, encompassing 42 square
miles of land approximately 30 miles northwest of Santa Fe in north central New Mexico. LANL
was established in 1943 for Project Y of the Manhattan Project to develop the world's first nuclear weapon. Currently, LANL is operated by the University of California for the Department of
Energy. LANL continues to conduct research in a variety of military and civilian areas.5
RCRA, as amended by the Hazardous and Solid Waste Amendments (HSWA) in 1984, requires
all facilities which involve the treatment, storage, and disposal of hazardous waste to obtain a
RCRA/HSWA waste facility permit. LANL complied with CEARP by initiating a process of
identifying potential release sites associated with LANL operations prior to filing a
RCRA/HSWA permit application. In the process of preparing the RCRA/HSWA waste facility
permit application to the U.S. Environmental Protection Agency (EPA), a total of 603 Solid
Waste Management Units (SWMUs) were identified as part of the requirements of the HSWA
Module VIII permit requirements.6 The HSWA Module VIII permit requires LANL to determine
whether there have been any releases of hazardous waste or hazardous constituents from
SWMUs at the facility dating from the 1940s by performing a RCRA Facility Investigation to
address known or suspected releases from specified SWMUs to affected media (i.e., soil,
groundwater, surface water, and air). Work plans for the RCRA facility investigations must be
submitted to the U.S. EPA for evaluation. The permit also requires LANL to take corrective actions for such releases.
50th Purdue Industrial Waste Conference Proceedings, 1995. Ann Arbor Press. Inc., Chelsea. Michigan 48118.
Primed in U.S.A.
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