ML20085G720

Draft-final, Environ Assessment Decommissioning Reactor Facility at Us Army Matls Technology Lab,Watertown,Ma

ML20085G720
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Site:	05000047
Issue date:	10/31/1991
From:	ABB ENVIRONMENTAL SERVICES, INC. (FORMERLY E.C JORDAN
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ML20085G716	List: ML20085G713 ML20085G718 ML20085G720 ML20085G725 ML20085G730
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Download: ML20085G720 (58)

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I I I iitii US Army Corps of Engineers Toxic and Hazardous Materials Agency DRAlT FINAL ENVIRONMENTAL ASSESSh1ENT DECOht!.11SSIONING Tile REACTOlt FACILITY AT Tile U.S. ARhtY MATERIAIS TECIINOLOGY IAllORATORY WATERTOWN, h1ASSACllUSETFS OCTOBER 1991 .

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• A8B ENVIRONMENTAL SERVICES, INC.

THAMA Form 45,1 Jul 90

DRAFF-MNAL ENVIRONMENTAL ASSESSMENT DECOSIS11SSIONING Tile REACTOR FACil,lTY AT Tile U.S. ARhtY h1ATERIAIS TECilNOI.OGY I AllORATORY WATERTOWN, St ASSACIlUSETTS Prepared For:

U.S. Anny Corps of Engineen lluntsville Division iluntsville, AI, and i

I U.S. Anny Corps of Engineers. .

Toxics and llazardous hiaterials Agency Aberdeen Proving Grounds, h1D Prepared fly:

Altli Environmental Services, Inc.

Southern New England Region Wakefield, MA OCTOllER 1991 1

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.; e TABLE OF CONTENTS DRAFT FINAL ENVIRONMENTAL ASSESSMENT FOR DECOMMISSIONING THE REACTOR FACILITY AT .HE U S. ARHY MATERIALS TECHNOLOGY LABORATORY WATERTOWN, MASSACHUSETTS Section Title Page No.

1.0 PURPOSE AND NEED FOR THE PROPOSED ACTION . . . . 11 1.1 PURPOSE AND NEED FOR ACTION . . . . . . 12 1.2 SCOPE OF THIS ENY'RONMENTAL ASSESSMENT . . . 13 2.0 REACTOR FACILITY .. . . . 21

2.1 BACKGROUND

AND HISTORY . .... . . . .. ....21 2.2 FACILITY DESCRIPTION ,.. .. . , 20 2.2.1 Physical Facilities .. ... .. .... . . ... 2-0 2.2 2 Radiological and Chemical Characterization . . . . . 2-8

3.0 DESCRIPTION

OF THE PROPOSED ACTION .. . .. . .. . 31 3.1 PROPOSED ACTION: DECONTAMINATION AND TOTAL DISMANTLEMENT 31 3.1.1 Decontamination . . .... .. .. . .. 32 3.1.2 Total Dismantlement Operations . . . . . ............35 3.1.3 Transportstion Operations .. . . ,. .. .. 37 3.1.4 Disposal Operations . . . . . ... ..... . . . 3-8 32 REGULATORY REQUIREMENTS . .. . . . .. 3 11 3.2.1 Fc6,ral Regulations . . . ., ... . . 3 11 3 2.2 State Regulations . .. .. . .. . . .. .. . . 3 15 3 2.3 Local Regulations . . ... . . . . . .. 3 19 3.3 PERMITTING ....... . .. .. . . . 3 t9 3 3.1 Federal Notification and Approval . , . . 3-20 3.3.2 State Notification and Approval . ... ...... ... . 3 20 3 3.3 Local Notification and Approval . . . ... . .. 3-24 4.0 ALTERNATIVES CONSIDERED . . .. . . ,. . . .. . ... . . 41 4.1 DECONTAMINATION AND PARTIAL DISMANTLEMENT . .. . 41 4.2 REGULATORY AND PERMirTING REQUIREMENTS . . . . .. . 4-3 4.3 INTERIM SAFE STORAGE . . .. .... . ..43 4.4 NO ACTION ALTERNATIVE . ... ... . . . .. ... 4-4 i 10/03/91 v~w.w w l

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l q e I TABLE OF CONTENTS DRAFT FINAL ENVIRONMENTAL ASSESSMENT FOR DECOMMISSIONING THE REACTOR FACILITY AT THE U.S. ARMY MATERIALS TECHNOLOGY LABORATORY WATERTOWN. MASSACHUSETTS J Section Titio Pago No 5.0 AFFECTED ENVIRONMENT . . . . . . . 51 5.1 PHYSICAL ENVIRONMENT . 51 5.2 LAND USE . . ... . ... . . . .. .. 51 53 WATER OUAUTY ,

. .. 52 5.4 AIR OUAUTY ,. .. . . . . 5-4 5.5 NOISE . . . . . .. . 5-4 56 ECOSYSTEMS . .. . . . , . . . . . . 55 5.6.1 Terrestrial Ecosystems . . . . 55 5 6 2 Aquatic Ecosystems .. . . 5-6 5.6.3 ' threatened and Endangered Speclos . 56 5.7 HISTORIC AND ARCHAEOLOGICAL RESOURCES . . 5-6 5.8 SOClOECONOMICS .. .. . .. . . 5-6 5.9 WASTE DISPOSAL . . . . .. 5-6 5.10 HEALTH AND SAFETY . . . . . . 59 6.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND THE ALTERNATIVES .. . .. . .,...... . .. .. .. . . 61 6.1 LAND USE IMPACTS .. .. . ... . . 6-1 62 WATER OUAUTY lMPACTS . . . . ... .. . .... . ... ......61 6.3 AIR QUAUTY lMPACTS . .. . . .. ..... . .... . . .. 6-3 6.4 NOISE IMPACTS . . . . .. .. . . . ...... .. ... . 6a 6.5 ECOSYSTEM IMPACTS . . . . . . . . . . . . . . . . ......... . 6-4 6.6 HISTORICAL AND ARCHAEOLOGICAL IMPACTS . . . .... .. ......64 6.7 SOClOECONOMIC IMPACTS . . .. . .. . . .. . . . . 6-5 6.8 WASTE DIFt'OSAL IMPACTS . . . . . . ...., . . . . . . . . 6-6 6.9 HEALTH AND SAFETY IMPACTS . . . . ..... . . . ... .... ..67 l 6.10

SUMMARY

OF IMPACTS AND ASSOCIATED MITIGATION FACTORS . . . 6 12 i

7.0 UST OF AGENOIES OR PERSONS CONSULTED . . . . .. .. . 71

8.0 CONCLUSION

S .

............... . . ..... ... .. ....61 i

9.0 REFERENCES

. ... ... . . . . . .. ... ,, , , . , 93 10.0 GLOSSARY OF ACRONYMS AND ABBREVIATIONS . . .. .. . , 10 1 il 10/03/91 e, w ,.<,a.4, .

• V TAULE OF COldTENTS DRAFT FINAL ENVIRONMENTAL ASSESSMENT FOR DECOMMISSIONING THE REACTOR FACIUTY AT THE U.S. ARMY MATERIALS TECHNOLOGY LABORATORY WATERTOWN. MASSACHUSETTS Section Title 11.0 UST OF PREPARERS . .. ... . . .. . 11 1 APPENDICES APPENDIX A RADIATION SURVEY RESULTS. ES. MATED VOLUMES OF WASTE AND ACCEPTABLE SURFACE CONTAMINATION LEVELS FOR TOTAL AND PARTIAL DISMANTLEMENT APPENDIX B ASBESTOS ABATEMENT AND BUILDING DEMOUTION REQUIREMENTS B1 FEDERAL (USEPA) AND STATE (DAOC) ASBESTOS ABATEMENT NOTIFICATION REQUIREMENTS AND FORMS B2 TOWN OF WATERTOWN. MASSACHUSETTS COURTESY NOTIFICATION PROCEDURES FOR DEMOUTION OF BUILDINGS (REQUIREMENTS AND FORMS)

APPENDIX C MASSACHUSETTS HISTORICAL COMMISSION RESPONSE TO DECOMMISSIONING OF MTL NUCLEAR REACTOR FACluTY APPENDIX D U.S. ARMY IMPLEMEN e ATION OF REVISED 10 CFR 20 lii 10/03/91 Wmte3 on f etycled paper

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, TABLE OF CONTENTS l DRAFT-FINAL ENVIRONMENTAL ASSESSMENT FOR DECOMMISSIONING THE REACTOR FACIUTY AT THE U S. ARMY MATERIALS TECHNOLOGY LABORATORY WATERTOWN, MASSACHUSETTS i

LIST OF TABLES l i

Tablo Title Page No.

21 IMPORTANT EVENTS IN THE HISTORY AND FUi' IRE OF DECOMMISSIONING OF THE MTL REACTOR FACIUTY , . .. .. ... .. . . . ., . .. ... 24 22 PAST DISPOSAL OF CONTAMINATED MATERIALS DURING THE 1970 DEACTIVATION OF THE MTL REACTOR FACluTY . . . . . . . . . ... . .. ... .... . . 25 i

3-1 FEDERAL LOW LEVEL RADIOACTIVE WASTE MANDATES FOR DECOMMISSION lNG THE REACTOR FACluTY AT MTL . .. . . . ... . ... . . .. . ...39 32 U.S. ARMY REGULATIONS APPUCABLE TO THE DECOMMISSIONING OF THE REACTOR FACluTY , . . . . . .... ...... . . . . . 3-12 3-3 PERMITTING AGENCIES AND REQUIREMENTS . . . ......... . .. ., , 3 22 6-1 ESTIMATED RADIATION DOSE FOR DECOMMISSIONING OF THE MTL REACTOR FACluTY . . . . , ........ . .. ... ... . . .. 60 6-2 ADMINISTRATIVE GUIDEUNES FOR RADI ATION WHOLE-BODY DOSES DURING DECOMMISSIONING . . . . ...... . ........... .... . 6 10 6-3 REGULATORY LIMITS FOR RADIATION DOSES DURING DECOMMISSICNING FOR A CALENDAR OllARTER ....... . . ,... ...,. ..... ... .... 6 10 04

SUMMARY

OF IMPACTS AND ASSOCIATED MITIGATION FACTORS . . . . . .. 6 13 81

SUMMARY

COMPARISON OF THE TOTAL AND PARTIAL DECOMMISSIONING ALTERNATIVES . . . . . . . . . . . ...... ............. .... .... . . 6- 2 8-2 COMPARISON OF SUBJECTIVE ESTIMATES OF IMPACTS DURING AND AFTER DECOMMISSIONING OF THE MTL REACTOR FACILITY ,.. . . . . . . 8-3 h/

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TABl.E OF CONTENTS DRAFT-FINAL ENVIRONk.. . ASSESSMENT FOR DECOMMISSIONING THE REACTOR FACluTY AT THE L 'MY MATERIALS TECHNOLOGY LABORATORY WATERTOWN, MASSACHUSETTS LIST OF FIGURES Floure Title Pa0e No.

21 LOCATION OF V S. ARMY MATERIALS TECHNOLOGY LABORATORY . . . . 22 22 GENERAL SITE MAP ..,. . .. . . .. . 2-3 2-3 MTL REACTOR FACIUTY . . .. . ... . .. . ... .. . . .. . 27 2-4 CROSS SECTION OF BUILDING 100. .. . ....... .. .. . 29 31 3AFETY MANAGEMENT STRUCTURE FOR THE DECOMMISSIONING PROJECT .. 3-3 32 SEQUENCE OF DECONTAMINATION AND TOTAL DISMANTLEMENT ACTIVITIES . . . . . . 34 33 FEDERAL REGULATIONS . . . ... ... . .. ..... .. .. .... . 3-13 34 STATE AND LOCAL REGULATIONS . . ... . . . .. . .... . 3 14 35 POTENTIAL LLW TRANSPORTATION ROUTE TO SOUTH CAROLINA DISPOSAL SITE . . 3 17 34 POTENTIAL LLW TRANSPORTATION ROUTE TO UTAH DISPOSAL SITE 4 . ... 3-18 3-7 FEDERAL, STATE AND LOCAL PERMITTING REQUIREMENTS . ... .. ... .. 3M1 41 DECOMMISSIONING ALTERNATIVES . . .. . . .... ... . .. . ..... ..42 51 HISTORICAL PROPERilES . . . . ... ,. ..... ......... ... . 57 l

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4 e EXECUTIVE

SUMMARY

This Draft-Final Environmental Assessment (EA) considers the decommissioning of the reactor facility located at the U.S. Army Materials Technology Laboratory (MTL) in Watertown, Massachusetts. The purpose of the action is to terminate the Nuclear Regulatory Commission (NRC) possession-only license (R45) for the roador facility.1ho proposed method for decommissioning is to decontaminato the reactor facility through the safe removal of low levol radioactive wasto (LLW) and other hazardous materials, followed by tho total dismantlement of the reactor facility.

This document is intended to help the NRC meet the National Environmental Policy Act (NEPA) requirements of 10 CFR 51.45 and 10 CFR 51.00, and to help the Army meet the NEPA requirements of AR 200-2 and 40 CFR 1500 3 The U S. Army is acting as a cooperating agency for this decommissioning action with the NRC. The Army understands the NRC will complete its own appropriate NEPA documentation and reach conclusions as to the potential environmental impacts after its review of this document. Once the NRC has completed its review and issues its conclusions in a final document, the Army intends to review and evaluato the NRC !!nal document. At that time, if the Army independently determSes the NRC document is legally complete and adequately addresses all factual issues, the Army may choose to adopt the NRC document under 40 CFR 1500 3 The Army may identify, study and evaluato additional or now onvironmental issues not addressed by the NRC; in which case the Army will prepare additional documentation as noodod before reaching its own independent NEPA datormination.

Factors contributing to the need to decommission the MTL reactor facility include the expiration of the roactor's NRC possession only license (R-65) in 1997 and the schedulod closure of MTL by 1995. The U S. Army operated the MTL research reactor from 1900 until its deactNation in 1970. During the 1970 deactNation, most of the radioactive materials and all nuclear fuol were removed and disposed of according to NRC and U.S. Army rogu!ations and approval, in 1988, the U S. Army initiated base closure procedures for the MTL facility, with'a schodu!od completion date of 1995. The reactor facility must be decommissioned and released by the NRC prior to its release for unrestricted use or transfer of j the MTL property. It is the Army's goal to prepare the reactor facility for transfer and rouse without restrictions. To accomplish this galt, the Army proposes to term 6mte the reactor facility's H-65 license through decommissioning.

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l' Additionally, MTL proposes to decontaminate the reactor facility prior to the todoral LLW disposal mandate which rnay restrict MTL's potential disposallocations, The mandato, passed in 1980 and amended in 1985, lequires disposal of LLW within the generator's state boundaries or at a facility located within a group of cooperating states (compact) (Public Laws 96 573 and 99 240). The Commonwealth of Massachusotts is currently not in conformance with the mandated schedule for constructing and operating a LLW disposal facility within the state or disposal in a compact stato, and disposal access to existing out-of-state sites may be discontinued on January 1,1993. Access could be denlod prior to 1993 If progress is not made In meeting those milestones.11 is the Army's goal to disposo of MTL's LLW prior to January 1,1993.

The five attemativos considered in this EA for the proposed deconimissioning are: (1) decontamination with total dismantlement, (2) decontamination with partial dismantlement, (3) safe storage, (4) entombment, and (S) no action. Safe storage and entombmont were not evaluated because they did not achieve the Army's objective of unrestricted use it was also determinod that the no action alternativo does not meet NRC requirements for terminating the NRC license (R-65), a requirement for decommission!ng, and therefore, it was not considorod in detail. The two altomatives dotormined to be in accordanc3 with the Army's objectivos, total dismantlement and partial dismantlement, are discussed in detall in the Decision Analysis Hoport (EG&G,19900).

The er$vironmental effects of the total and partial dismantfoment attemativos woro evaluated comparatively (see Section 8.0). Table ES 1 summarizes the rotativo short-term and long term adverse offects and bonofits of those alternatives. Only smali decreases in quality of the specifin environmental attributes are anticipated for each alternativo during the decommissioning operations, except for total dismantlement's impacts on historic resources. This moderate decreate in quality of historic resources is related to the loss of the reactor facility; however, this will be mitigated by the preservation and documentat'on of specific control room equipment photographs, operating records and any other

• artifacts identified and preserved prior to the initiation of decommissioning. Additional mitigation measures will be implomonted to further reduce other temporary adverse impacts.

Partial dismantlement would create smaller decreases in quality duo to the reduced scale and length of operation. These roduced impacts would be related to sodiment in surface water runoff, groundwater ES-2 10/03/91 hole 3 Oft Ffcytted pai,0f

TADLE ES 1 COMPARISON OF SUBJECTIVE ESTIMATES OF IMPACTS DURING AND AFTER DECOMrAISSIONING OF THE MTL REACTOR FACILITY WATERTOWN, MASSACHUSETTS Altornatives t ibute DECONTAMINATION AND DECONTAMINATION AND No Action PARTIAL DISMANTLEMENT TOTAL DISMANTLEMENT During After During After Physical Environment (Soils) 0 1 0 -1 42 Land Use 0 -1 0 -1 +2 Water Quality 0 1 0 2 41 Air Quality 0 1 0 2 +1 Noise 0 -1 0 2 NE Ecosystems 0 1 0 1 +1 Historic Resources

• 0 +1 -1 -1 -2 Archaeological Resources 0 0 0 +1 0 Socioeconomic 0 +1 NE +1 NE Radiological Conditions 0 1 +1 1 +1 0= no chango 1= small decrease in quality 2= moderate decrease in quality 41 = small increase in quality

+2= moderato increase in cuality

• A survey is required. Mitigation may be required under the Historic Preservation Act.

NE - Not evaluated. Will be based on future use of MTL ES-3

• < p quality, alt quality due to dust, and noise due to the demolition of concrete and steel. Total dismantlemeu, while exhibiting a slightly higher level of short-terrn adverse impacts, would ultimately provide a greater increase in quality upon the completion of the decommissioning operations. These enticipated increases occur in the physical environment and land use opportunities for the public (unrestricted use and possible transfer of the property) and increased land area for diverse native flora and fauna. Both partial and total dismantlement would meet the U.S. Army's base closure schedule.

Long term socioeconomic impacts were not evaluated due to the uncertainty regarding future reuse of MTL Interim safe storage, on site or at another licensed facility within Massachusetts, may be a necessary contingency for either partial or total dismantlement if Massachusetts does not comply with the federally-mandated schedule or if the currently operating sites chcae not to receive waste from Massachusetts. A facility for Interim safe storage will be constructed on site if neodod. This on-site storage may require an amendment of an existing NRC license or approval of the Decommissioning Plan. The application of NRC and U.S. Army approved storege and monitoring methods would assure protection to public health or the environment. Interim safe storage would be used until access to a disposal site, in or out of.

state, is granted. Ulumate disposal of the stored waste must be accomplished by 1995.

This EA concludes that the decommis'iloning of the MTL reactor facility is not a major action significantly affecting the environment. The propo'ted action also does not affect the environmental impacts or charga the conclusions of the facility's base closure Environmental Impact Statement (EIS) (CE,1991).

Therefore, a supplement to the MTL's EIS in not required (40 CFR 1502.9)

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1.0 PURPOSE AND NEED FOR THE PROPOSED ACTION The U S. Army Materials Technology Laboratory (MTL) of the U S. Army Laboratorv Command (LABCOM), a subordinate command of the U S Army Materiel Command (AMC), is pursuing the termination of their possession only license lf 65) luuad by the Nuclear Regulatory Comtris11on (NRC, formerly the Atomic Energy Commission). This will be accomplished by decommissioning the reactor factiRy located in Watertown, Massachusetts. The licensee is the Commander of the MTL facility, Major Melvin Adams.

This Draft Final Environmental Assessment (EA) has been prepared in accordance with National Errvironmental Policy Act (NEPA); Massachusetts Environmental Policy Act (MEPA), and U S. Army Regulation (AR) 200 2 requirements to evaluats potential environmental Impacts of the proposed decommiss;oning of the reactor facility. This EA also meets the requirements Ier an Enviror, mental Report as outlined in NRC regulaDon 10 CFR 51.45. The purpose and need for the proposed decommissioning is desedbed in Section 1.1 and Sectinn 12 describes the scope of this EA.

This document is Intended to hel .ne NRC meet the NEPA requiroments of 10 CFR 51.45 and 10 CFR 51.60; and to help the Army meet the NEPA raquirements of AR 200 2 and 40 CFR 1500 3. The U.S.

Army is acting as a cooperating agency for this decommissioning action with the NRC. The Army understands the NRC wWI complete its own appropriate NEPA documentation and reach conclusions as to the potential environmental impacts af or its review of this document. Onco the NRC has completed its review and issues its conclusions in a final document, the Army intends to review and evaluate the NRC final doc'.iment. At tha.t time, if the Army independently determines the NRC document is legally complete and adequately addresses all factual issues, the Army may choose to adopt the NRC docun.ent under 40 CFR 150R3. The Army may identtfy, study and evaluate additional or new environmental issues rmt addressed by the NRC; in which case the Army will prepare additional documentation es neoded before reaching its own indepcident NEPA determination.

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i 1.1 PURPOSE AND Nf,fD FOR ACTIQN in 1970, MTL completed the deactivation of the Horace Hardy Lester nuclear research reactor, During the 1970 doactivation. most radioactive materials and all nuclear fuel were removed and disposed of (soo Section 2.1).

MTL is now preparing to terminate their NRC possessionGly license (R-65) because the research roactor has ceased coeration ar.d MTL must completo decommissioning of the reactor faciltty without any furtf'or delay (Title 10 Code of Federal Regulations Part 50.82,10 CFR 50.82). A Decommissioning Plan has boon prepared based on this federal regulation. Decommissioning of the reactor facility will be conducted to moet the unrestricted use enteria establishod by the NRC (1974,1987) and assure the potential reuse or transfer of the site. Once the decontamination has been completed, verified with 4 confirmatory surveys, the R 65 license will be terminated.

Under Public Law 100-526 The Base Closure and Realignment Act (BRAC) (October 1988) and the Defense Commission Report of Base Realignment and Closure (December 1088), the MTL facility is scheduled for c!osure by 1995. The U S. Army initiated base closure acticns in 1988 and is scheduled to complete the base closure by September 30,1995. It is the Army's goal to prepare the MTL facility for trantir and reuse without restrictions to a non federal agency. To accomplish this goal, the Army proposes to terminate the reactor facility's R-65 !!conse through decommissioning.

MTL proposes to decontaminate the reactor facility in accordance with two federal LLW disposal mandatos. The Low-Lovel Radioactive Waste Policy Act of 1980 (P.L 9GMM, as amended in 1985 (P.L.

9240). provides milestones for states and regional compact members to provide for disposal of LLW generated within their borders. States fallbg to meet these milestones may lose access for their generators to the three existing LLW disposal sites by January 1993 (Soction 3 2.3). Access could be denied prior to 1993 l' progress is not made in meeting these mitostones. Another potential facility for the disposal of a large portion of MTL's LLW is the Envirocare facility in Utah. This facility is not regulated by the federal disposal mandate and thorofore may accept MTL's LLW. It is the Army's goal to dispose of MTL's LLW prior to the January 1,1993 deadline.

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12 SCOEg OF THIS ENVIRQNMENTAL ASSESSMENT TNs Draft-Final EA addresses the potential environmental impacts of decommissioning methods for the teactor fael!Ity at MTL lt will be used by the U S. Army and the NRC to evaluate the significance of any adverse impacts, select the most suitable alterrutive for decommissioning, and document the results in a Final EA.

This document is based on Information contained in existing environmental documents cited herein by reference. This tiered format (40 CFR 1502.20) is pos31tJe because detailed reports describing the baseline environmental conditions at MTL, the radiological and chemical characterization of the reactor facility, and the costs, risks, and impacts associated with decommissioning altemativos have already been completed. These documents include the following:

(1) Characterization Report for U S. Army Materials Technology Laboratory Research Reactor (EG&G 1990a).

(2) Decision Analysis Report for U.S. Army Materials Technology Research Reactor (EG&G,1990b).

(3) Decommissioning Plan for the U.S. Army Materials Tect.nology Laboratory Research Reactor (EGSG,1991a)

(4) Demolition and Reclamation Plan for Building 100 at U.S. Army Materials Technology Laboratory at Watertown, Massachusetts (EG&G,1991b)

(S) Final Environmental impact Statement for the Army Materials Technology Laboratory Closure (CE,1991)

By incorporating and summarizing data (by reference) from existing environmental documentation arKl plans portaining to the proposed decommissioning, this report eliminatos repettive discussion of subjects that have already been thoroughly documented.

This report presents the infomiation nooded to evaluate decommissioning altomatives in a comparative manner and includes a consideration of regulatory requirements and potent'ai beneficial impacts.

Section 3.0 provides a description of the proposed action and briefly addresses the regulatory requirements and federal, state, and local permits required for the decommissioning project. Section 4.0 describes the attematives considerod. Section 5.0 characterizes the existing environment at the MTL.

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The environmental and soclooconomic consequences of the proposed action and atternatives are prescriled in Section 6 0.

Becaut,e decisions regarding the future land uses of the MTL after base closure have not been made, all the changes that may occur after decommissioning and post closure cannot be fully evaluated at this time. However, decommissioning, which requires that the reactor facility be decontaminated and teleased with no restriction on the property's future uso, will avoid any potential long term risk to the public health and the environment.

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l 2.0 REACTOR FACluTY P 1 BACKGROUND AND HISTORY The MTL reactor was the first nucioar research reactor designed to rneet the neods of the U.S. Army Ordnance Corps research programs on materials. It was constructed at Watertown, Massachusetts (Figure 21), during the late 1950t The MTL site layout is presented in Figure 2 2. The reactor was dodicated on May 17,1960, to the memory of the late Horace Hardy Lester, who won national recognition as a plonoor of industrial radiography.

Irnportant events that mark the research reactor's past or influence its future are presented in Table 21.

Various solid-state physics research programs and experiments were conducted at the 1 MW power level through June 1906 by the U.S. Army Materials and Mochanics Research Conter (AMMRC). The reactor was also used extensNoly by the U.S. Army Picatinny Arsenal for study of explosNe-typo materials. Other U S. Army users included the Detroit and Frankford Arsenals as well as the Natick Research, Development, and Engineering Center and Electronics Technology and Devices Laboratory.

Some of the programs conducted by the reactor users includod: experiments in the structure of heavy.

metal azides, lattice dynamics studies on explosNo type materials, determinations of vibrational spectra of organic secondary explosNes, polycrystalline and single crystal coherent scattering materials and liquids, activation analysis of samples containing trace impurttles, and induction of slight radiation effects in materlats (EG&G,1990a). In addition, several local institutions (Boston College, Worcestor Polytechnic Institute, UnNersity of New Hampshire, and the Massachusetts InsGtute of Technology) also used the MTL reactor for diffraction measurements and irradiations.

In 1909, the U.S. Army dockied to shut down the operation of the reactor and to place it on standby status. Shut down was accomplished in March 1970, following which, fuel elements were removed under NRC and U.S. Army approval. Irradiated and unirradiated fuel elements and othst materials were disposed of, and coolant systems were drained. Table 2 2 presents a summary of past dispor31 of contaminated material from the MTL research reactor facillty. DeactNation was completed in June 1970, and a deactivation report was submitted to the DNision of Reactor Licensing and the U.S. Army Reactor 21 10/03/91 w,w s.nw.a

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mum i- l WATERTOWN, MASSACHUSETTS

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asa _ _ _ _ _ - . . _ _

I

e.. g. t TABLE 2-1 IMPORTANT EVENTS IN THE HISTORY AND FUTURE OF DECOMMISSIONING OF THE MTL REACTOR FACILITY WATERTOWN, MASSACHUSETTS DATE EVENT 1968 Reactor Construction Initiated I 1960 Reactor Construction Completed, Ucensed, and Dedicated l

1960 1966 Reactor licensed at 1 MW 1968 Reactor license amended to 2 MW 1969 Reactor license amended to 5 MW U.S. Army Decision to Shut Down Reactor and Place on Standby Status 1970 DeactivationCompleted ReactorPlacedinStandbyStatus Deactivation Report Submitted to the DMslon of Reactor Ucensing and the U.S. Army Reactor Systems Health and Safety Review Committee

• 1971 NHC approves amendment of license R45 to

• possess!on-only' status 1942 Massachusetts Moratorium on in state burial of LLW (MGL Cnapter 503) 1985 Preseret industrial Radiography Experiments 1968 -

initiation of Base Closure Actions (Public Law 100-526) -

1992- _ Federal Moratorium (Public Law 96-573 and Public Law 99 240) which limits out of state disposal of Low Level -

Radioactive Waste (LLW) -

1995 MTL Scheduled for Closure (Public Law 100-526) i 1997 Research Reactor R 65 Ucense Expires 2-4 i

l

. ,. - _ . . . _ . , . _ . . . _ - . _ . . . _ - . . . _ - _ , - . . - _ . . - - . . . - . . . . - - . - . . . .. ... - _ ~ . . , ~ . . . , . . . . . - . . . . _ . _ - _ . _ _ ~ .

.e e TABLE 2 2 PAST DISPOSAL OF CONTAMINATED MATERIALS DURING THE 1970 DEACTIVATION OF THE MTL REACTOR FACILITY ITEM DISPOSITION Fuel elements containing U.S. Atomic Energy Commisslori special nuclear materlais and irradiated fuel elements Unitradiated fuel elements National Lead Co. (cor. tract)

& materials Be( Alector elements, shim-safety Nucicar Engineering Co.

rods, armatures, magnets, stainless steel portions of the guide tubes Fission chambers with Another reacior facility, reported under Uranium-235 SNM 24d tonizing chambers As low level radioactNe wasto RadioactNe sources fc U.S. Army Radiattori and Occupational calibration Safety Branch Notes:

' Special Nuclear Material Licer'se Sources:

AMMRC,1970 EG&G,1990a,b.

2-5

. s.

l I

Systems Health and Safety Review Committee in December 1970 Following deactivation. MTL amended its operating license to a possession-only license, Since deactivat6on, the use or the reactor faciitty has been limited to conducting P variety of industrial radiographic experiments in the containment building The experiments are condacted using a portable neutron generator and scaled sources of Californium 252 as a neutron radiation source. Only small sources of radiation are used so they do not activate other materlats. The sxperiments are Shlolded as necessary and no air emissions. water discharges, or hazardous waste are produced. Radioac'Ive wat,te and by-products are disposed of in accordance with AR 38511 and AR 385-80, as well as NRC licenses R45 and SNM 244 issued to MTL Radioactive source materials are disposed of by retuming them to Department of Energy (DOE) 09 the case of Califomium) or to licensed producers (personal communication, Dr. J. Antal. MTL,1991). Current NRC licenses held by the MTL tacility are as follows:

1. BML204101044 (Broad Scope), atomic numbers 343. Hydrogen 3, Cobalt-00, Ceslum 137, Polonium-210, Americium 241, Califomium 252, expiration date 30 June 1989*.

2. SUB-238, Thorium and Uranium 238, expiration date 28 February 1901*

3. SNM 244, enriched Uranium and Plutonium 239, expiration date 31 August 1992.

4. R45, possession only license for the research reactor (Bullding 100), expiration date 2 October 1997.

• MTL's license renewal application has been submitted and is pending NRC's decision.

22 FACILITV DESCRIPTION R1 Physical FacliHigg The components of the reactor faciliy include Building 100, portions of the adjacent 6ullding 97, and Cistem 242 that is located approximately 25 feet (7.6 meters, M) southwest of Building 100 (Figure 2-3).

These buildings and components are described in detall in earlier documents (EG&G,1990a; 1990b).

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1 Building 100 is a cytindrical pressure vessel 80 feet (24 4M) in diameter, approximately 67 feet (20.4M) high from grourd level, with an elliptical top. A cross section of the Building is shown in Figure 2 4. The basement extends about 19 feet (5.8M) below grade and a 6 foot (1.8M) diameter gamma-ray facility extends an additional 9 feet (2.7M) below the basement level. The buildng is a gas tight conteinment shell with perimeter walls consisting of concreta,2 feet (0 6M) thick cnd extending 44 feet (13.4M) above ground to the crano rails The exterior of the containmerit vessel is covered on the outside with one-half inch (1.3 centimeters, cm) welded steel ano all utility lines einer through air tight connections The entrance for personnel is through an air lock in Building 97; a second aidock exists on the south side of Building 100.

Cistern 242 is s buried retention tank that was designed to hol6 roautor pool water during reactor maintenance to reduce the time and expense of supplying demineralized water to refill the pool (EG&G, 1990a). It is a 23.5-foot (7.2M) square tank constructed of 1 foot (0.3M) thick concrete. It is 15 feet (4.6M) deep. A manhole cover prosides access to the tank's interior, in 1966, a liquid-level indicating recorcer was installed to permit a means of monitoring the tank for any appreciable leakage.

2 2 2 Ragljolooical and Chemiqal Characterizatign, Tha e ' actor was shut down in March 1970 and placed in a standby condition. During the deactivation process, . dioactive materials were removed from Building 100 and 97 and d4posM of as indicated in Table 2-2 Water from the primary and seconda y coolant systems, secondary coolant sump, the main reactor pool, fuel storage tank, and Cistern 242 was drained and disposed of according to standard NRC and U.S. Army procedures (EG&G,1990a).

There are no known records of a significant release of reactor-pool water inside the reactor. During initial criticality in 1960, minor leaks of reactor coolant, water through the concreto biolog! cal shield were observed. Over the next year, construction methods were used to reduce the leakage (EG&G,1901a).

In 1966, a stain:ess stoet liner was installed in the reactor-pool to completely eliminate the remaining minor leakage. The reactor pool water that leaked through the biological shield did not cause any major contaminatinn to spread outside the shield, however, it is estimated that aoproximately 50 percent of the 28 10/03/91 NifTted OP NSCyt. led P6DCf 1

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concrete shield is contaminated. There were other smaller occurrences at the reactor facihty causing leakage of the reactor pool water (EG&G,1991a). In each Instance, corrective actions were completed.

An unplanned release of approximately 14,000 gallons of radioact ve liquid waste occurred from Cistern 242 between February 20 and 27,1969. MTL's health physicist reported a total actMty of 30 micro curies (uCl) rr.4easeo. The tank's remaining contents were sampled after the relene and the gross actMty was determined to be 5.7 x 10' uCl/mi (EG&G,1991a). The Reactor Facility Safety Committee concluded that the release was less than 10 percent of the limit set by the NRC in 10 CFR 20, Appendix C for permissible burial of radioactive waste in soilr therefore, there was no hazard. A verification of soil conditions near the reactor faclitty will be conducted beginning in October 1991. This work will include the installation of a monitoring well directly downgradient of Cistem 242, and the collertion and analysis of soils from an area downgradient of the Cistern (USATHAMA,1091).

Characterization surveys (September 1989) of the reactor vessel, remaining ccmponents and Building 100, Indicated only low levels of rad!oactivity (Tables A-1 and A-2) and chemical contamination. This evaluation vas based on the most restrictive NRC guidance (NRC, 1974,1987), which recommends acceptable surface contamination levels for removable contamination of less than 200 disintegrations per minute (dpm)/100 ctd beta gamma-emitting nuclides and 20 dpm/100 crd alpha-emitting nuclidos.

Water sampled from Cistem 242 during February 1990 indicated that radioactivity is well within drinking water standards (EG&G.1990a). Analyses of sediment and soli taken from around Clstem 242 and the reactor facility (March 1990) did not detect eny alpha- cr gamma emitting nuclides, or hazardous materials (metals, lead, mercury, and Appendix !X analytes: EG&G,1990a) above USEPA regulatory limits (40 CFR 261). Appendix IX analytes are a list of compounds included in EPA regulations 40 CFR 264, whose ans!yses are required for the closure of a hazardous waste treatment, storage and disposal facility. This charactoraation was done to ensure the quality of the groundwater beneath the reactor facility.

During the March 1990 survey, the pining in Building 97 was also sampled to determine the levels of radioacttve contamination. These survey results indicated that the radioactivity did not exceed the 2-10 10/03/91 Preted ort Recycled Paper

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acceptable surface contamirution levels (alpha and beta gamma emitters) specified in the NRC guldelines (NRC, 1974,1997, ANS,1981) and are presented in Table A+

The additional rnatorials and components that have been identified as contaminated, or any additional )

materials discoverod during either punial or total dismantlement will be handled, packaged, transported, and disposed of in a manner consistent with all existing fedoral, state, and local regulations. Regulatory 1

requirements and nocessary permits are discussed in Sections 3.2 and 3.3. respectively Materials characterized as LLW will be disposed of at an NRC authorized LLW disposal site.

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3.0 DESCRIPTION

OF THE PROPOSED ACTION A range of potential altematives for decommissioning the MTL reactor facility, according to NRC guidance documents (1974,1984), were considered in this EA. These alternatives included total or partial dismantlement (each preceded by decontamination), safe storage, entombment, and no action.

Total and partial dismantlement may also include interim safe storage as part of the decommissioning process. Based on the evaluation presented in the Decision Analysis (EG&G,1990b), the Decommissioning Plan (EG&G,1991a), and this environmental assessment, the proposed action is decontamination of the MTL reactor facility followed by total dismantlement. This proposed action is discusod in this section of the EA and the remaining alternatives considered are discussed in Section 4.0.

The U.S. Army has prepared the Decommissioning Plan for the termination of the NRC possession-only license (R-65). This plan describes the a ' contamination activities and precautions to be taken, a safety analysis of the decontamination activities, and a safety analysis of the MTL slte in its unrestricted use status. The Decommissioning Plan will be reviewed along with this EA by NRC and the U.S. Army to select the appropriate alternative.

3,1 PROPOSED ACTION: DECONTAMINATION _A.ND TOTAL DISMANTLEMENT The proposed decommissioning operation of the reactor facility includes decontamination followed by three general operations: dismantlement, transportation, and die- ~ a The decontamination encompasses the safe removal of radioactive contamt. ants and asbestos, as well as other hazardous materials, and is followed by total dismantlement of the reactor facility. Transportation involves the packaging of the waste (LLW, chemically hazardous waste, and uncontaminated waste) and the intrastate / interstate transfer of wrste materials to an authorized waste disposal site. The disposal operation addresses the disposal site selection and method of disposal.

The estimated cost for the decontamination and total dismantlement of the reactor facility is approximately $5,300,000 to $6,100,000 (EG&G,1991a). This estimated cost range is based on the void ratios of the waste packaging (10 to 60 percent) and the assumption that the LLW is disposed of 31 10/03/91 Proted en Aecyded Paper l

- - - - _ .. - _ = -

. y between January 1.1992 and January 1,1993. These costs do not includt. the removal of the asbestos, which is estimated to cost between 512,000 to $19,000 (TRC,1990). Detailed costs are presented in EG&G 1990b and 1991a.

3.1.1 Decontaminatiqo The decontamination the MTL reactor facility will be initiated by isolating areas of the faellity that contain radioactive contamination and ashestos. These areas will be cordoned off based upon the results of available contamination surveys and requirements specified in the Decommissioning '!an (EG&G, 1991a). The containment structu e will provide secondary containment for protection of the surrounding environment until the radioactive wastes and asbestos from within Building 100 are removed. The reactor facilny decontamination activities will be performed in accordance with all applicable regulatory ,

and safety requirements as specified in the Decommissioning Plan. Figure 3-1 represents the management structure of the decommissioning project relative to safety (EG&G,1991a). Figure 3 2 presents the general sequence of construction activities and subsequent confirmatory surveys.

The following structures and equipment will be removed during the decontamination of the reactor facil$

. Cistem 242

. Building 97 piping

. Secondary coolant system

. Reactor pool internals and annulus

. Reactor pool liner

. Platforms surrounding the reactor pool

. Basement electrical system

. Basement piping and equipment

. Basement sumps

. Gamma-ray Facility and storage tubes

. Reactor pool 3-2.

10/03/91

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l NRC i (LICENSEE) MTl_

MTL RADIATION COMMANDER CONTROL

COMMITTEE 1- l NEW ENGLAND. MTL DIVISION TECHNICAL-  :

CONTRACTING MONITOR / RADIATION OFFICER PROTECTION i u OFFICER d,

INDEPENDENT CONTRACTING OUALITY -

OFFICERS REPRESENTATIVE

\ ASSURANCE t EVAlijATOR/HP CONTRACTOR PROJECT MANAGER j

[ '

RADIATION CONTROL AND SAFETY OFFICER [

HEALTH PHYSICIST CERTIFIED HYGIEN!ST

! ' QUALITY ASSURANCE EVALUATOR a

t i

FIGURE 3-1 SAFETY MANAGEMENT STRUCTURE FOR THE DECOMMISSIONING PROJECT

' MTL REACTOR FACILITY

_ SOURCE: EG&G,1991a WATERTOWN, MASSACHUSETTS

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Y y CONTRACTOR REMOVES, PACKAGES, AND DISPOSES OF LLW; DECONTAMINATES 4_..._.._._g TO NRC RELEASE CRITERIA 1 e

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CONTRACTOR CONDUCTS SURVEY TO ENSURE SITE ------- EEos,,, ,4 E* -

IS DECONTAMINATED l 1

NOT EACEED in l

AEHA CONDUCTS exceeds CONF 1RMATORY SURVEY

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NRC ISSUES ORDER TO TERMINATE POSSESSION ONLY .

UCENSE R45 h

LICENSE R45 TERMINATED (TIME) 1r CONTRACTOR DISMANTLES

~ REACTOR BUILDING in REMOVAL AND DISPOSAL OF CONSTRUCTIOrd DEBRIS d

CONTRACTOR CONDUCTS SURVEY TO CHARACTERIZE .

THE SITE y 4

AHEA CONDUCTS SURVEY TO CHARACTERIZE

- THE SITE 4

CONTRACTOR RECLAIMS SITE WITH CLEAN F1LL CONTRACTOR CONDUCTS .

SURVEY TO CERTIFY THE SITE e

[ AHEA CONDUCTS SURVEY TO CERTIFY THE SITE

4 FIGURE 3-2 l 8'IE AvA B' SEQUENCE OF DECONTAMINATION p qp E AND TOTAL DISMANTLEMENT ACTIVITIES t

MTL REACTOR FACILITY WATERTOWN, MASSACHUSETTS

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l These items will be surveyed for radioactive contamination. Those exceeding NRC criteria will be packaged for off site disposal. If the radioactive contamination is removable, these items may be decontaminated and salvaged for reuse.

Confirmation of the reactor facility decoatamination will be ensured by the survey for fixed and remove.ble alpha and beta gamma residual contamination. Survey procedures will incorporate principais presented in NUREG/CR 2082 and those presented in Chapter 8 of the Decommissioning Plan (EG&G, 1991a). All survey results must be below acceptable NRC criteria for unrestricted use of the s!!e (NRC, 1974, 1987).

Independent radiological and asbestos surveys have been corducted in the reactor facility by EG&G (EG&G,1990a) and TRC Environmental Consultants, Inc. (TRC,1990), respectively. EG&G has determined that mixed wastes (radioactive hazardous wastes) are not expected to be encountered during the dismantilng of the reactor facility (EG&G,1990b). EG&G and TRC estimated the quantitles of LLW (miscellaneous concrete surfaces and piping) and asbestos. The quantity of LLW is estimated to rarige between 7,425 cubic feet (CF) (210 cubic meters, CM) and 11,138 CF (315 CM), depending on the voids (estimated to be 10 to 60 percent) created during th6 packaging of the waste (EG&G,1990b). The anticipated range of radioactivity levels of the LLW are presented in Appendix A (Tables A-1 and A 2) and are based on the radiological surveys conducted in the reactor building (EG&G,1990a). The quantity of asbestos to be removed is approximately 720 square feet (SF) (67 square meters) and consists of 115 SF of friable asbestos and 605 SF of non friable asbestos (TRC,1990).

Fol!owing the decontamination of the reactor facility, the contractor, the U.S. Army, and NRC will conduct independent surveys to confirm that any fixed and removable alpha and beta-gamma residual contamination is below NRC unrestricted use critena (NRC 1974,1987). Upon completion and verification of the decontamination, the NRC will terminate the possession-only license. R-65.

31.2 Total Dismanttement Ooerations This section generally describes the activities required to demolish the reactor facility remaining after the removal of all contaminated components as described Section 3.1.1 of this EA and in the 35 10/03/91 w,m wamn

v s.

Decommissioning Plan. The termination survey of the remaining reactor building structure wdl have been performed in accordance with the Decommissioning Plan to ensure that the remaining structure is uncontaminated, and the MTL reacter facility will have been released for unrestricted use. However, the demolition activities will be monitored by health physics technicians in order to check previously inaccessible surfaces and areas for radioactMty. If any radioactively-contaminated components, material, or other items are detected during demolition, they will be immediately separated and contained for dlsposal.

Total dismantlement will include the removal and disposal of the following items:

. alriocks e dome roof e crane

. shell

. Intemal concrete wall

. basement floor This proposed action includes the demo!.'tlon and disposal of Building 100, the reactor containment shell, the polar crane, and two air locks. These items will be disposed of as clean waste. To continue to support buildings 292 and 297, the electric substation transformers and pad, and unthodic protection system will be relocated to another location at MTL to suppo!t other nearby buildings. The control room equipment can be removed and presersed if it is not a threat to the public health and safety or the environment, arxi is determined to have historical value. If any of this equipment poses a risk to the health and safety of the public, it will be disposed of accorWng to applicable regulatory requirements (EG&G,1990b; 1991a). EG&G cstimated the quantity of uncontaminated solid waste (general construction rubble) to be approximately 5,000 tons (4,535 tonnes), as presented in Table A-3 (EG&G, 19905).

Following the total dh,mantlement of the reactor fact!!ty, a second characterization will be conducted to determine and docuinent that no radioactive or chemical contaminants exceeding regulatory criteria remain at the site. Any remaining contaminated materials or soil will be removed and disposed of as -

3-6 10/03/91 Nnted On Recycled Paper

,, e required. The site will then be backfilled, gruded, and landscaped to match the surrounding area. A l final survey will be performed at the site (EG&G,1991a) to certify that residual contamination levels meet NRC release criteria (NRC 1974, 1984,1987). This action wili open the area to unrestricted use.

3.1.3 Transoortation Operations Both the LLW ard asbestos will be packaged and transported, according to all fedeml and state regulations. The uncontam!nated solid waste has minimal packaging requirements and will be transferred to an authorized local disposal site, i

The U.S. Army Armament, Munitions and Chemical Command (AMCCOM) is the Army's LLW manager.

Packaging, loading, and shipping of LLW will be supervised and certified by AMCCOM in accordance with AR 38511, Otner federal regu!ations (Section 3 3.1) require that radioactive material be packaged to ensure that the packaging will be sufficiently strong under conditions incident to normal i tranaportation. NRC regulations provide a set of performance criterla for the containers, rather tnan l specific design requirements, to remove the need to predict specific accident events and circumstances, and to provide a set of engineering test speufications. These NRC pedormance criteria and test l specifications are based on evaluations of actual accidents (NRC,1980). The Depaitment of t

[ Transportation (DOT) has also issued regulations covering all aspects of transporting radioactive wastes.

l - These regulations specify container requirements, mechanical condition of the transport vehicle.

personnel training requirements, labeling, and shipping documentation (10 CRF 71; 40 CFR 262; 49 CFR 170-199), DOT also conducts carrier equipment inspecticn.

'All of the federal packaging requirements (Section 3.3.1) are further based on the International Atomic

- Energy Agency (IAEA) radioactive classifications and properties of the materials. The radioactive material resulting from the dismardement of the MTL reactor facility will be categorized as Low Specific

. Ac'Ivity (LSA) Radloactive Material (10 CFR 71,4 (g)). The IAEA defines this LSA material as " inherently safe' regarding radiotoxicity, This type of waste must be contained in strong and tightly soa!ed packaging, generally consisting of 55 gallon drum = and special tank trailers, which permit no leakage of.

radioactive material. This waste will be transportw primarily using the Interstate highway system and avoiding large population centers, as much as possible, minimizing the risk of vehicular accidents. The I _

3-7 10/03/91 Prmttid Ch Aecycled Paper l

LLW can currently be transported to one of three commercial disposal sites, located in South Carolina.

Washington, and Nevada. The LLW may also be transported to a licensed disposal facility in Utah that is not mandated by the federal LLW mandate.

The asbestos material wul be wetted, packaged (double bagged or drummed); and labeled in accordance with the applicable regulations. The asbestos will then be transported to an Siuthorized disposal site by a licensed hazardous material carrier. The uncontaminated solid waste wul be transported to a local facility authorized to accept construction debris.

31.4 Disoosal Operations Locations and methods of disposal will vary depending on the type of waste. Under the terms of the federal Low Level Radioactive Waste Policy Act, the Commonwealth of Massachusetts is responsible for the prop-- ' wl of LLW generated within Massachusetts. The act mandates states to establish and operate e a facility within their boundaries or form a compact with another state (s) for the purpose a L' . lsposal. Further, the Waste Policy Act of 1980, as amended in 1985, requires that the establishment of the disposal facility be accomplished in accordance with a muestone schedule (Table 31), Unti January 1,1993, waste-generatl J states that are delinquent in meeting the milestone schedule are assessed a surcharge penalty by the three existing disposal facilities. Currently, the surcharge penalty included in the generators disposal fee is $40/CF ($1,413/ cubic meter) of LLW disposed and wHI increase to $120/CF ($4,238/ cubic meter) in January 1992. After January 1,1993, the existing faci lltles can refuse to accept the waste and the federal govemment will retum a portion of the surcharge account to the Individual generators for their use to facultate on-site storage of their LLW. The Commonwealth of Massachusetts has not joined a compact and is not in conformance with tha

- milestone schedule (Table 31).

Furthermore, the Commonwealth has passed legislation (MGL Chapter 503) prohibiting the disposal of LLW within its boundaries. Massachusetts is currently threatened with access denial to the existing out.

of state ! LW disposal sites if progress is nos made on the federally-mandated schedula. MGL Chapter 503 will have to be repealed before the Commonwealth can make progress toward the establishment of ,

a disposal facility.

36 10/03/91 P'mted on Recycled Paper

TABLE 3-1 7

FEDERAL. LOW LEVEL RADIOACTIVE WASTE MANDATES -

' FOR DECOMMISSIONING THE REACTOR FACILITY AT MTL.

WATERTOWN, MASSACHUSETTS '

Low-Level Radioactive Waste Policy Act of 1980 (P.L.96-573)

Requires each state to La responsible for the " disposal of low-level radioactive waste generated 1 withlu its borders except for waste generated as a result of defense activities of the secretary (DOE) or federal research and development -activities. .."

Low-Level Radioactive Waste Policy Amendments Act of 1985 (P.L. 9J-240)

Reaffirms the policies of the 1980 Acti provides milestones, incentives and penalties to encourage states and regional concpacts to fulfill 'their responsibilities for ensuring disposal capacity.

511esto es incentives Penalties Before July 1,.1986, earch state shall . 25 per cent of the Failing any milestone:

join'a regional compact or certify its . federally-mandated surcharge intent to develop an in-state low-level fees paid by producers of LLW

• Triple the normal ,

waste facility to the three sited states (S. generator surcharge I

+

, carolina, Nevada and shall be paid by waste

• Defore January'1, 198b, each compact Washington) shall be rebated producers

, 'y shall designate a host. state, or each. to the state for meetirig each

, e single state shall develop a facility- milestone.

• Waste producers siting procedure shall lose access to, t

+ Af ter January 1, 1993, the the three disposal

, . Defore January '1, .19 90, each state or three sited states may deny sites in S. Carolina,

!' compact shall file..a license access Nevada and Washington  ;

application to operate a disposal t facility or certify the' state'is both

• On January 1, 1996, if a .

• State shall lose l

" capable of providing," and "will'. state or compact is unable to rebate monies provide" for storage, disposal or provide disposal' capacity, the i

management of LLW requiring' disposal state shall "take title to the after 1992 waste, be obliged to take i possession of the waste, and *

. Defore January 1, 1992, each. state or shall be liable for all compact shall file a license to operate damages directly or indirectly t a disposal facility (final deadline) incurred by such generator" as a result of failing to take l -

Dy January 1, 1993, if a state or possession of the waste

' compact is-unable to provide disposal capacity, (1) LLW generators may 1' request state to take possession of waste, or.(2) if state or compact is developing disposal capacity, the 25 per cent surcharge shall be returned to  ;

generators, not'to the state I

l REF: BAA L1RW,1990 6633 40 ,

i

< w

The three existing LLW disposal facilities are located in Bamwell, South Carolina (oporated by Chem l Nuclear Systems, Inc.), Richland, Washington, and Beatty, Nevada (both operated by U.S. Ecology, Inc.). Currently, the preferred out-of stato disposal site is Chem-Nuclear Systems in Bamwell, South Carolina, based on analyses conducted by EG&G (1990b). Both the U.S. Ecology sites require a longer transport distance than the Chem Nuclear site, increasing the cost and potential for an inc!dont. In addition, the Nevada site requires a lengthy permitting schedule and has expensive disposal feos.

1 A fourth LLW disposal site exists in Clive. Utah and is operated by Envirocare of Utah, Inc. This disposal l facility was only recently licensed (March 1991) by the Stato of Utah and is now being considered as a potential attemative for LLW disposal. This facility is not regulated by the federal LLW disposal mandato.

Envirocare of Utah may accept the LLW generated by the decontamination and dismantling of the reactor facility, provided: it meets the material restrictions stated in the disposal facility licenso (UT 2300249), and either the Commonwealth of Massachusetts provides export approval or the Stato of Utah, Bureau of Radiation Control, and Nodhwest interstate Compact approves the acceptance of the LLW. A representative of Envirocare Mr. Kurt Higgins, reviewod the swipe survey results from the MTL reactor facility characterization report (EG&G,1990a). He made an initial dotermination that almost all of the LLW generated by the decontamination of the reactor facility could be accepted at their facility, except for some material from the reactor annulus. Some of the isotopes and their radiological activity may exceed Envirocare's license conditions. Final review of the LLW lsotopes and their activity would be required prior to the actual transportation and disposal of the LLW at the Utah facility.

The asbestos will be disposed of at a hazardous waste landfill specifically licensed for asbestos, Olsposal areas within the Nonheast region include: BFI Chicopee Sanitary Landfill, Chicopee, Massachusetts; Tumkey Landfill, Rochester, New Hampshire; Waste Management, Inc., Norridgewock, Maine; and Sawyer Environmental Recovery Factory, Hampdon, Maine. The method of disposal involves the off loading of the packaged ascestos into a lined cell, which is then immediately covered with clean impermeable backfill to castrict the percolation of surface water through the cell and into the groundwater.

The uncontaminated solid wasta (l.e., below NRC,1987 criteria and non hazardous) will be disposed of at a locallandfill authorized to accept construction debris. Authorized disposal sites within eastem 3 10 10/03/91 Pnnted on Flecyded Paper

,,. v Massachusetts include: Stump and Demolition Landfill, Barnstable; Ravenbrook Farms Demontion Lindfill, Marshfield; and Johnson Steel and Wire Facility Worcester. The method of disposal will involve the discharge of the solid waste into a cell, with spechied levels of clean fill and impermeable capping material.

12. REGULATORY REQUIREMENTS The decommissioning of the MTL reactor facility win be conducted in conformance with all applicable U.S. Army, federal, state, ard local regulations. These regulations are identified in Table 3 2 and Figures 3-3 and 3-4, and are related to the requiraments for protection of the work force, the pub'ic, and the environment. Compliance with these U S. Army, federal, state and local regulations are met, in part, by the submittal of permit / notification applications and their approvals (Section 3 3). Regulatory compliance is also met through monitoring and submitting documentation outing the decommissioning i operations.

3 2.1 Federal Reoutations The Decommissioning Plan for MTL identifies the decontamination methods, schedule and projected post <fecontamination survey to the NRC for approval, Once approved, decommissioning can proceed  !

and the NRC will monitor the decommissioning operation. After the post-decontamination survey has been cornpleted by the Contractor and the U.S. Army Environmental Hygiene Agency, and it is confirmed that the site meets a standard where there is no restriction on the property's future use (NRC, 1974; 1984,1987; and ANS,1981), the NRC will conduct a confimutory release survey. The NRC will terminate the MTL possession-only license R-65 when they have completed their survey and determined that the site is available for unrestricted use. The license may be terminated prior to the actual dismantling of the reactor facility (Figure 3 2).

The removal of the LLW and asbestos, and dismanticment of the containment building will be done in accordance with regulations implemented and enforced by the U.S. Army, NRC, USEPA, and OSHA.

3-11 10/03/91 PttDfed Of1 Recycled PBper

n-

-.4 ..

TABLE 3 2 U.S. ARMY REGULATIONS APPUCABLE TO THE DECOMMISSION!NG OF THE REACTOR FACluTY

- AR 40-5: Preventive Medicine (October 1990)

- AR 40-14: Control and Recording Procedures for Exposure to lonizing Radiation and Radioactive Materials -(March 1982)

AR 200-1: Environmental Protection and Enhancement (April 1990)

- AR 200-2: Environmental Effects of Army Actions (December 1988)

- AR 385-11: lonizing Radiation Protection (Licensing Control, Transportation Disposal and Radiation Safety) (May 1980) s AR 385-80: Nuclear Reactor Health and Safety (April 1991)

AR 405-90 D!sposal of Real Estate (May 1985) 3-12

p

I {'

.l 6'

I NUCLEAR REGULATORY COMMISSION I

l l 10 CFR 20.101 to 108 GUID ANCE DOCUMD*T STANDARDS FOR REGULATORY GUIDE 1.86 TERMINATION ANS1/ANS PROTECTION AGAINST T o p O! p g OF NON-POWER

RADIATION REACTOR LICENSE 15.10-1981 l l (NRC,1984)

DECONTAMINATION '

AND l OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION l

I DISMANTLEMENT -,,,,,,,,3 ASDESTOS PROTECTION AND EXPOSURE STANDARDS U.S. ENVIRONMENTAL PROTECTION AGENCY 1

l 40 CFH 61 end 763 r ASSESTOS PROTECTION STANDARDS I i

U.S. ARMY AMCCOM l

l l AR 385-11* l NUCLEAR REGULATORY COMMISSION i ._ -.

J

' JD CFR 71 2

NRCPACKAGING AND I

j p ,. TRANSPORTATION OF RADIOACTIVEMATERIALS

TRANSPORTATION U.S. DEPARTMENT OF TRANSPORTATION l I

nummmuammmmm mamens- nummammemamamme mammma 31CFR 173 49 CFR 177.821 S U 39 CFR 172 RADIOACTIVE ROUTING AND HMARN MATERIALS AND TRAINtJG AF TY 1

GENERAL NATERIALS REQUIREMENTS ASBESTGS REOUIREMENTS REGULATIONS REGULATIONS l __

U.S. ENVIRONMENTAL PROTECTION AGENCY l 40 CFR 61and 712 ASSESTOS PACKAGING hEGULAT10NS U.S ARMY AMCCOM l i

AR 38511* l y

NUCLEAR REGULATORY COMMISSION l I -

I 4-y 13 CFR 20301 to 311 ItLCFR 8155 to 57 2k OM MST E DtS5'OSAL WASM CLASSNAN. k 3. > c D!SPOSAL  %

W n REGULATIONS CHARACTERISTICS AND LABELJNG ** s~e O

l- - ?5 ap E o U.S. ENVIRONMENTAL PROTECTION AGENCY l p

40 CFR Etand 763 WASTE DISPOSAL Q REGULATIOt4S FIGURE 3-3 U.S. ARMY AMCCOM g FEDERAL REGULATIONS

} ~

MTL REACTOR FACILITY  ;

5%

g .auea vo riste s-2,ca corriount xaur neoutation.

AR 385-11*

l WATERTOWN, MASSACHUSmS i i

j . . , . .

1 ,

,, o .

MASSACHUSETTS' i

DECONTAMINATION 2aan2a^=

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. ma' ~ * = -

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W e tt #'4 L S

=~'- ""'"'

w a tt ma w tTt t&L DISMANTLEMENT ,

WATERTOWN, MASSACHUSETTS' t

i 12M!IG 111ALA,ltL,JL1LE2.21 weec4*o o : wona MASSACHUSETTS I

i l

utexu <suv.u utm2ts:Anarm: .2taam Tg SpO p= 4 __ *Acancewa ct '1tanspostanog os smam asu sTot  !

45H5739 AHE STOS 40 ADW A1 ; 3440G4 nahowwg ACCCSS R(QWREMENT1 CONNECTICUT auimuum SLL".MA A@d TnemsscNTanow asawntuggf1 44@0 ACTIV4 M4fD Akt i

MASSACHUSETTS I i i unmumswa '

DISPOS %AL - attmla til cun a

. 1312dLt.9 o en un uniToi omm u.uTo. ...o..t 35BCM44 Af 3UinfMEW9 Alf LBA(M61CS R E QL.84 EWE W1 4

SOUTH CAROLINA I

netan A Aac A071vt mSposai F aciUTT UCEmid AMO W ASTE ,

CL ASS.BIC AMON r

FIGURE 3-4 STATE AND LOCAL REGULATIONS 4

I NO STATE OR LOCAL ARIS01CT1CN oN FE0rR4L PROPERTY. HOWEVE" NOTIFICA TION IS RECOMMENDEO. MTL MEMR FERW 1 ST4 TE REGUuTIONS BASED ON THE PCTIN11AL 1RANSPORT ROUTE OF THE LLPW. PREPARED BY TRI STATE MOTOM TPANSIT. Jopt:N. MO.1 14-9 t.

WATERTOWN, MASSACHUSETTS acace 3-14

. . - _~ .. . .~ . _ _ _ - - .- - . _ _ - - - . . - .

.s ,,

The NRC regulates the radiation protection of workers, the public, and the environment during the LLW removal. These NRC regulations are based on guidelines prepared by the USEPA. The USEPA and OSHA further regulate worker prctaction for the asbestos removal. These federal regulations are kjentified in Figure 0-3.

The transfes of radioactive material is regulated by the AMCCOM, NRC and DOT. AMCCOM is responsible for analntaining records for the Department of the Army on the type and quantity of radioactive waste disposed, managing Army contracts for buttal of radioactive waste at licensed burial sites in the U.S., and ensuring that these contract terms and cond'tions are satisfied. The NRC regulates packaging and release of the material to a carrier through licensing requirements. The DOT regulates the carrier by means of special placards and transportation routing. The USEPA regulates the packaging of the asbestos in conjunction with the DOT transportation requirements.

The NRC is the only federal agency that regulates the disposal of the LLW at licensed LLW disposal sites, These regulations govem the waste classification, characterization, labeling, and disposal of the LLW. The USEPA regulates the disposal of the asbestos at licensed hazardous waste landfills.

The U.S. Army regulations apply to all waste (1 e., LLW, asbestos, and so'id waste) generated by decommissionin0 the reactor building. These regulations cover decontamination, dismantiement, ,

transportation, and disposal (Table 3 2).

The Department of Energy (DOE) does not have any jurisdiction over the decommissioning of this facliity as their regulations only govem the activities at DOE-owned and operated facilities.

3.2.2 State Reoulations The applicable state regulations for the waste, resulting from decommissioning of the MTL reactor facility, are identified in Figure 3 4. Five Massachusetts state agencies regulate the transportation and/or -

disposal of LLW, asbestos, and uncontaminated waste from the reactor containment build lng. These agencies include the Department of Public Health (DPH), the Division of Air Quality Control (DAOC),

3-15 10/03/01 Pneted on Recycled Paper

,, s Division of Solid Waste (DSW), DMslon of Industrial Safety (DIS), and the Division of Hazardous Waste (DHW).

No state agencies have jurisdiction over work being conducted on federal property. Therefore, the decontamination and dismantlement of the reactor facluty must only be done in conformance with federal regulations. However, the Massachusetts Low Level Radioactive Waste Management Board and the DPH will be notl'ied of the proposed work to be conducted at the MTL facility, which will involve the generation of LLW. Additionally, the Massachusetts DAOC and dis will be notified prior to the removal of asbestos from the reactor building.

The packaging requirements for LLW are regulated by the AMCCOM, NRC and DOT: the states have no jurisdiction in this area. However, the states do have jurisdiction on the transfer of the LLW to the disposal site. These regulations may include travel time and weight restrictions, and documentation requirements. A potential transportation route for the transfer of LLW from Watertown, Massachusetta, to Bamwell, South Carolina was prepared by Tri-State Motor Transit of Joplin Missouri, and is presented in Figure 3-5. Bamwell is used here for illustrative purposes because it is the closest facility to Watertown.

The same approach will be used if another facility is selected. If this potential routing is selected, both the Massachusetts Metropolitan District Commission (MDC) and the State of Connecticut will have applicable regulatory requirements. Both regulatory requirements can be avoided by routing the LLW shipments around MDC roadways, from the MTL facility to Interstate I-90, and around Connecticut via 1-90 and I-67, as shown in Figure 3 5. The potential disposal of the LLW at the Envirocare facility in Utah is czrently being evaluated by the U.S. Army because it is likely that some waste material will go tu Utah. A potential transportation route for the transfer of LLW from Watertown, Massachusetts to Clive, Utah is presented in Figure 3-6.

The trarsportation of the asbestos falls under the jurisdiction of the Massachusetts DAOC and OlS.

Further, access permission for the transport vehicles on MDC roadways and bridges is required from the MDC. The transportation of the uncontaminated solid waste to a locallandfill will r.ot be regulated beyond the Massachusetts weight restrictions for trucks on the state highways and bridges (Massachusetts Department of Public Works), and the access permission of MDC roadways and bridges, as mentioned above.

3-16 10/03/91 PFTted O'1 Recycled Puer 1

POTENTIAL LLW TRANSPORTATION rot.fTE (TA!P LENGTH APPROX.1,200 MILES)

US 20 to I 90 to I l-84 (alt.1-87) to I-380 to o

I-28to US 321 to b""*" "" I <

l f RTE. 3 to '

RTE 64 to Disposal Site ,,,j .

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, my' ,

t 4 -

MTL FACILITY WATERTOWN, MA VA

[ __

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~ +_ CHEM-NUCLEAR SYSTEMS, INC.

V, BARNWELL, SC 9

i l FIGURE 3-5 POTENTIAL LLW TRANSPORTATION ROUTE TO SOUTH CAROLINA DISPOSAL SITE MTL REACTOR FACILITY l 7=>u WATERTaWN.11ASSACliUSETTS. l 3-17

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. NY WATLHlOWN. tAA

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ENV1HCCARE OF UTA4 tNC, #

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't POTENTIAL LLW TRANSPORTATION i ROUTE  ;

(TRIP LENGTH APPROX. 2,500 MILES) .

i US 20 to A l l-90 to >

1-84 1o . [

I-81 to .

la ta i

' FIGURE 3-6  :

,'73, POTENTIAL LLW TRANSPORTATION

• a0 to Disposal S!te ROUTE TO UTAH DISPOSAL S5TE .  !

MTL REACTOR FACILITY i WATERTOWN, MASSACHUSETTS ,

'4630 00 .

. - - - - - . - . - . - . . . . . . - . - . . - - . . - - - . . - . . - - _ - . - . . . . - ~ . .

,s e

Disposal of the LLW in Massachusetts is regulated by DPH, and, further, disallowed by state legislation  ;

- enacted in 1982 (MGL Chapter 503). Due to the lack of an in-state disposal site, the LLW is proposed to be transported and disposed of in Bamweh, South Carolina. South Carolina is an agreement state, under the NRC's Agreement State Rules, which licenses and it'.spects the operator of the Bamwell disposal faclity, Chem Nuclear Systerns. The licensing and enforcement regulations are based on the NRC disposat regulations in 10 CFR 61.

The disposal of the asbestos wu1 be completed in compliance with Massachusetts DIS, DSW and DHW regulations. Additional disposal requirements may be applicable if the proposed disposal site is located outside Massachusetts. The DSW also regulates the disposal of uncontarninated solid waste within Massachusetts. These regulations are enforced through the disposal facility license approval and waste classification criteria. The selection of the proposed landfills for disposal of the asbestos and -

uncontaminated solid waste will be based on transportation arxf disposal costs, and volume of waste to be disposed of (iandfill capacity).

223 Local neoulations The Town of Watertown, Massachusetts, does not have jurisdiction over work being conducted on

federal property, and according to legal precedent, cannot regulate the transportation of LLW: howevor, the applicable town departments (e g., Board of Health) will be notified by the U.S. Army prior to the initiation of decommissioning. The town zoning by-laws require the prior notification for building demoiltion, with specific concems for asbestos removal, rodent control, and town emergency response team _ notification. MTL and the Town of Watertown_ also have a Memorandum of Agreement (MOA) -

related to the provision of fire fighting services to the facility (MTL,1991). - As a result of the reactor -

• facility decommissioning. MTL must inform the town fire chief of proposed significant clanges in -

occupancy and the hazards that will affect fire fighting tactics, as spec:fied in this MOA. Local regulations do not apply to any other work proposed for the decommissioning of the reactor building.

3 3 ' PERMITTING Permits for decontamination will apply to both partial and total dismantlement activities. Compilance 3 19 10/03/91 Pnnted on Recycled Peper

,,. ~

r with the federal, state and local regulations, presented in Figures 3 3 and 3-4 are met through the submittal of permit / notification applications and their approvals. The decommissioning of the MTL reactor facility will require the submittal and approval of both federal and state permit / notification applications. Although not required, the state and local agencies will be notified of the decontamination and dismantlement operations on federal property. These regulatory agencies and their permit / notification applications cre identified in Figure 3-7. Table 3 3 further presents detailed information of the agency contacts, filing fees, and review and approval schedules.

3.31 Federel Notification end Aporo._ val The Decommissioning Plan has been prepared by the U.S. Army concurrently with this EA. Both reports will be submitted to the NRC, AMCCOM and other applicable U.S. Army organizations for their review and subsequent approval of the proposed action No actions will be taken without prior NRC and U.S.

Army approval of the Decommissioning Plan.

The USEPA Region i Offico must be notified at least 10 days before the removal of asbestos is to begin, per 40 CFR 61. This requires the completion of a notification form providing facility and contact information, quantity, data, removal procedures, and identification of the waste disposal site. A sample notification form is presented in Appendix B-1.

3 31 State Notification and Anoroval A permit must be o~.ained from the MDC and Connecticut Depart.nent of Transportation (CTDOT) for the interstate transportathn of the LLW to the proposed disposal site in South Carolina. Should the transportation of the asbestos or solid waste also be on MDC roadways or bridges, prior access approval must be provided by the MDC's Permitting DMslon. However, Commonwealtn of Massachusetts and State of Connecticut requirements can be eliminated by routing the transportation of all wastes around MDC roadways and bridges, and bypassing the state of Connecticut as presented in Figure 3-5.

l

[_

3-20 10/03/91 Annted on Recycled Pacer

I i

NUCLEAR REGULATORY COMMISSION 1

tcCFR5cft FEDERAL --- 't a * *^ * * **"c t"St-DECOWh4S$0'4NO PLAN U.S. ENVIRONMENTAL PROTECTION AGENCY

.... .,0. =_._ i MASSACHUSETTS i

S' TATE """"*

_ mASSF e"".STOS REWOV AL kOT'ACA DON

""""m""'"""

g ACCESS NOT1FICADON*

m CONNECTICUT unsem -> cm ECCli'iAand INTERSTATE PERMT

• LLRW TRANSPORTATION LOCAL WATERTOWN, MASSACHUSETTS I

ZOMNQ BY. LAWS ART. !I SEEf. 001 NOTI'1

+ CAT 804 Of WORK FIGURE 3-7 FEDERAL, STATE AND LOCAL PERMITTING REQUIREMENTS MTL REACTOR FACILITY PsRgeAN

, , ee mmarta

, av Amoma uteme WATERTOWN, MASSACHUSETTS 3-21

TABLE 3-3 PERMITTING AGENCIES AND REQUIREMENTS FEDERAL . Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 (301) 492 0240 No filing fee Approval of Decommissioning Plan

. 40 CFP. 61 U.S. Environmental Protet.t on Agency Region 1 JFK Federal Building Boston, MA 02203 ATTN: NESHAPS Coord;nstor No filing fee 10 day notification prior to asbestos removal (see Appendix B)

I i . Commander

' U.S. Army Armament, Munaior.s & Chemical Command ATTN: AMSMC-SFR (Mr. Byron Morris)

Rock Is!and. il 61299M)0 No filing fee Notification prior to LLW generation / removal SfATE e Commonwealth of Massachusetts Low Level Radioactive Waste Managemerit Board 100 Cambridge Street, Room 003 Boston, MA 02202 No filing fee Notification prior to LLW generation / removal

. 105 CMR 120 and 410 Massachusetts Department of Public Health Radiation Control Program State Laboratory Instdute 305 South Street Boston, MA 02130 No filing fee Notification prior to LLW generation / removal

. 310 CMR 7 Massachusetts D partment of Environmental Protec*Jon Northeast Region 5 Commonwealth Avenue Woburn, MA 01801 ATTN: Div. Air Quality Control No filing fee 20 day notification prier to asbestos removal 3-22 ,

1

l TABLE 3-3 PERMITTING AGENCIES AND HEOUIREMENTS (continued)

• 453 CMR 6 Mastachustus Department of Labor and industries DMslon of Asbestos Control Technict! Services 100 Cambridge Street Boston. MA 02202 No fillrt to da' ,

... nation prior to asbestos approval

. Matrachusetts Metropolttan District Commbston Permming DM$lon 20 Somersett Street B9aton, MA 02202 No fling fee 10 day notification prior to transportation of any waste e GENERAL STATUTES OF CONNECTICUT SECTION 19-409d Connecticut Department of Trarraportation DMslon d Motor Transit P.O. Box 310998 Newington, CT 00131

$50/ Vehicle load of Lt.W 13 days review / approval schedule j,QQAk . Zoning Bylaw Art. IX Sect. 9 01 Town of Watertown, MA 149 Main Street Adminiuration Building Watemown, MA 02172 No flii p fee 1 J . sy raview/ approval schedule 3-23

The Massachusetts Low Level Radioactive Waste Management Board arv.i DPH will be notified of the proposed decontamination and dinmar,tlement of the reactor facility, due to the generation of LLW.

According to Massachusetts regulations. the notification of the DAOC and Department (4 Labor and it,dustnes (DU) e minimum or 20 and 10 days, respectively, is also recommended prior ) the removal of the asbestos. The required information for the DAOC and DLl (DIS) is tho same as specified for the l USEPA Region i notification (Appendix B'1),

.;Ludocal Notifipation and Apptgvgl No local permits are required for the dec')mmissionirig of the MTL reactor facility; however, the Town of Watertown, Massachusetts w.41 be notified of the proposed reactor facility decontamination and dismantiement, shiprnent schedutos, and routes of LLW transportation. This notification will conform with the town zoning by laws (Article IX, Section 9.01) concerning asbestos removal, roderst control, and emergency response team notification (police, fire and DPW). In crder to conform with the terms of the existing MOA between MTL and th6 Town of Watertown (MTL,1991), the Watertown Fire Chief will be notified of changes in occupancy or hazards resulting from decommissioning activities. The notification forms are enclosed in Appendix B 2.

l WIBD-3 24 10/03/91 r,m.un neyc u.v.,

-- -. , -- . . . - , , - - - , ~ - , . _ . . - -_.__,,.e. -

. . - . . , - .- . _ , . , . . . - . . ... . m,-, ,. . . . . , , . -

. - - - - - - _ . - . - - - ~ . . -- - --. - -- .-

4.0 ALTERNATIVES CONSIDERED Fke pitomatkes, total and partial dismantlement precodod t;y docontamination; safe storage; ontombment; and no action were initially consiriorod for decommissioning the reactor facillty and termina*ing MTL's NRC licenso (R 65). Based on a revkw of NRC regulations (10 CFR 50.2 and 50 82; NRC,1974; ANS,1981; 32 CFR 651) and earlier reports (EG&G,1990b), only total dismantlerr.ont arx1 partial dismantlement were identified as feasible altemativos (Figure 41). The proposed action, decontamination and total dismantleraont, is discussed in Section 3 0. The remaining altomativos considered are discussed in this section.

The safe storaDe, entombmont and no-action attornatkos were eliminated because they do not satisfy the requirements for terminating the NRC licenso (to CFR 50.2). NRC regulation 10 CFR 50.2 defines decomtvissioning as '..10 reduco residual radioactivity to a levol that permits release d the property for unrestricted use and termination of the licenso.' Further, those attornatives do not support the proposed base closure scheduled for 1995 or achieve the U.S. Army's objective of unrestricted use. The no action attemative, which delays decommissioning to permit natural degradation of radioactNe rnatorials, also does not meet the NRC toquirements for licenso termination (to CFR 50.2 and 50.82; NRC,1974). NRC regulation 10 CFR 50.82 (b)(1)(ll) states that the decommissioning process must be completed Mthout significant dolay, except when nocessary to protect the public health and safety, As mentioned previously, total and partia! dismantioment may also include interim safo stnrage of LLW materiale as part of the decommissioning process. An interim storago area may be constructed on site and may be contingent on amonding an exist;ng NRC storago license (SUB 238) or by approval of the Decommissioning Plan. Interim storage would only be used until access to a disposal site is Orantod.

4.1 DECONTAMINATION AND PARTIAL DISMANILfffg.N,_I Decontrmination and partial dismantoment involve the removal of all radioactivo material whose actMty levels exceed NRC unrestricted use enteria (NRC 1974,1987).. No further dismantlement of the reactor facility is required once it has been approved for unrestricted use and the possession only license R-65 4-1 10/03/91 n,%,, no,-.v.

. - . , . , . - . - , . _ . _ . ,_ - , . . - , , , . , . . , . , . - . , . . - , . , , . - . _ , , , -, - - , - - . . , , . .--n,., , , - , .

' T 1  !

DECOf4TAMINATIOt4 DECONTAMINATION ErlTOMBMENT IJO - ACTION SAFE STORAGE AND TOTAL AND PARTIAL DISMANTLEMEf4T DISMANTLEMENT _

\ /

ELIMINATED ELIMINATED ELIMINATED

\ / BASED ON TifE I BASED ON THE BASEDOriTHE g 7 FOLLOWitiG: FOLLOW!!4G: FOLLOWING l'

\ - 10 CFR 50.2 - 10 CFR 50.2 - 10 CFR 50.2

' ' ^ "

- 10 CFR 50.82 - Impacts Base Impacts Base TORAGE Closure Closure

- 32 CFR 651 Schedule Schedule (AR-200 2)

I i'" NRC Regulatory y Guide 1.86

(

• DISPOSAL '

• OF LLW

• Impacts Base Closure Schedule i

l T l

TERMINATION OF NRC LICENSE R-65 t

FIGURE 4-1 DECOMMISSIONING ALTERNATIVES MTL REACTOR FACILITY -

~

WATERTOWN, MASSACHUSETIS ,

~

Q45 'lO

i terminated by the NRC. Decontamination of the reactor facility would be performed by the same methods presented in Section 3 for decontamination prior to total dismantlement.

The stt :' containment shell, concrete liner with polar crano, basemont, operating floor, and the air lock between Buildings 97 and 100 would be left intact for possible reuse. A cover would be placed over the space left by the removal of the reactor vessel. Partial dismantlement would temporarily displace ongoing experiments, which upon completion of the dismantlement, could continuo in the refurbished contalnment building.

Quantitles of LLW and asbestos, and the potential disposal locations will be the same for partial and total dismantlement Only the quantity of uncontaminated sobd waste generated by both alternatives will differ. EG&G estimsted the quantity of uncontaminated wasto to be approximately 470 tons (420 tonnes) for partial dismantlement versus 5,000 tons (4,535 tonnes) for total dismantlement.

The estimated cost for the decontamination and partial dismantloment of the reactor facility is approximately $4,300,000 to $5,100.000 (r.G&G,1991a), not including asbestos removal ($12,000 to

$19,000 (TRC,1990)). This estimated cost range is based on the void ratios of the waste packaging (10 to 60 percent) and the assumption that the LLW is disposed of betwoon January 1,1992 and January 1, 1993.

4 2 REGULATORY AND PERMITTING REQUIREMENTS The regulatory and permitting requirements for partial dismantlement will be the same as those for tctal .

dismantlement due to the operational similarttles of the two decommissioning options. These regulatory and permitting requirements are presented in Sections 3.2 and 3.3.

4.3 INLERIM SAFE STORAGE Because of the federal mandate on out of stato LLW disposal, the possibility exists that interim storage.

of LLW on-site or at another licensed facility within Massachusetts may be necessary for olther total or partial dismantiementJ An existing NRC license may have to be amended to permit the interim storage 43 10/03/91 c m oena m eara w

- . , , . . , . - -_,,r. - - ~ . . , , . . , . . . _ - . ....,-,.4_-,_2__-. - . . . . - . . ~ . - , , - .,......_,.s __..,m-_-. , . -..s_

of the LLW or authcrtzation will be received from the NRC by their approval of the Decommissioning Plan. A facility for interim safe storage would be constructed on-site and used untu access to a disposal site, in or out-of state, is granted. Ultimately, MTL's LLW must be removed of by 1995, in accordance with the scheduled base closure. .

t

/3 regulatory approved schedule to monitor the LLW for any leakage of low-level radioactivity would be Implemented. At a minimum, the LLW will be stored in a locked and secured area, and would be -

monitored by inventory checks and radioactive swipe surveys on a quarter 1y basis (NRC,1974; ANS; 1981). An environmental radiation survey should also be performed semi annually to verify that no significant amounts of radiation have been released to the environment. Existing monitoring prograrns for other NRC-licensed actMtles may be modtlied to inch >de the interim safe storage area. The compatibulty of the existing monitoring programs with requirements for interim storage will be bat.ed on the radioactivity levels of both the wastes and the use of the areas abutting the storage area (i.e., other mater'.at storage, offices, production, ctc.).

4 4 NO-ACTION ALTERNATIVE The no-action alternath soes not most the NRC requirements for license termination (10 CFR 50.2 and 50.82; NRC,1974). This a!!ematha involves a delay in dismantlement until natural degradation of radioact Fve materials reaches a level cons stent with NRC unrestricted use critoria (NRC, 1974; 1987),

This attemath/9 is not feasible because it would significantly impact the scheduled base closure and further delay Qe completion of the decommissioning process (reactor shutdown was initiated in 1970).

The U.S. Army would be further delayed in presenting the base in a condit!on acceptable for unrestricted use and poter'llal disposal of the property.

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5.0 AFFECTED ENVIF10NMENT 31 PHYSICAL ENVIRONMENT The Dreater Boston area consists of geomorphic districts resulting from several structurally controlled bedrock domains (Skehan,1979). The MTL is located within one of these domains known as the Boston Bash and is predominantly underiain by siltstone of Pennsylvanian Cambridge Argillite. Other rock types found within the Boston Basin include meta sandstone, meta conglomerate, and meta volcanic units (Zen,1983). The unconsolidated sediments lying above beurock in the greater Boston area are comprised of various glacial tills, glacio fluvial sands and gravels, and rnarine clays.

Based on the installation et soll borings and monitoring wells, and a seismic refracation survey of MTL, approximately 45 to 120 feet of Quatemary sediments have been deposited over the argillite bedrock. A generalized ascending stratigraphy consists of: a basal till of silty gravel; a moderate to well-sorted silty, fine grained sand; a medium to coarse gralned sand; and fill material or disturbed sand and gravel. A more detailed description of the physical environment around MTL is provided in the " Basic Closure Environmental impact Statement (EIS)' (CE,1991) and geotechnical report (USATHAMA,1988).

5 2 LAND USE The MTL site consists of a total of 37 acres (15 hectares) which are used by the post and are owned by the U.S. Army Most of the MTL site possesses an industrial character with large brick buildings. Fifteen buildings on post occupy approximately 550,000 square feet (51,100 square meters) (CE,1991).

The land at MTL was recently re-zoned in 1988 from Mixed Industrial to Open Space /Conservat!on (OSC). The present zoning classtfication will not affect use by a federal agency, however, if the property is sold to a non federal ent'ty, r the property would rovert to the classification of Open Space. Open Space is defined in the 1990 Watertown Zealng Ordinance (Zoning,1990) as:

' Areas open and unobstructed to the sky that can be useo for active or passive recreaticn purposes. Benches, walkways, pools, atriums, trees. flagpoles, sculptures und similar structures or ent100s shall not be considered obstructions; parking and loading areas of any type shall not be allowed in any required open space "

51 10/00/91 Prhted ott Retycled Papef i

1 Towns surroundi,.g MTL inciude Watertown, Belmont, Waltham, Cambrktge. Newton. Ariington, Somerville, and Brookilne. The primary land use for these communities is rosklential (55 percent of the total acres). The area immediately surrot.nding MTL and most of the area cast of Route 128 has an urban resident lal character w!th umerous parks (CE,1991).

13 WATER QUALITY Water quality 's regulated under the Federal Clean Water Act and the Massachusetts Clean Water Act.

The Massachusetts Surface Water Quauty Standards designate the uses for which the various rouriace waters of the Commorrwealth shall be enhanced, maintained and protected.

There are several water resources within the portion of the Charles RNor Watershed near Watertown, such as Sawins Pond, Halcyon Lake, Chandler Pond. Chestnut Hill Reservoir, Choose Cake brook, Crystal Lake, and Bulloughs Pond. No surface water bodies exist within the MTL site boundaries (CE, 1991). MTL is adjacent to the northern bank of the Charies River, approximately sly miles west of the rNor's mouth at Boston Harbor (Figure 2 2). The entire MTL facility is above the 100 year floodplain (FIRM 250223002B; 9/30/80).

Water classification standards have been established for the Charies River by the Commonwealth of Massachusetts. Recent data suggest that the water quality of the Charies River is improving.

The river has been gNon a classification of *B* from the Watertown Dam to the Science Park Dam in Boston (314 CMR 4.05). This classification means that the water is suitable for recreational boating; as a habitat for wildlife and common food and game fishes indigenous to the region; for certain industrial cooling and process uses; for public water supply with appropriate treatment uador some conditions; and irrigation of crops used for consumption after cooking.

Surface water currently drains from the MTL faciltty in a south-southwesterly direction towards the Chades RNor. An existing storm sewer system currently collects the surface water runoff from the facility and other properties adjacent to MTL (PA/SI,1988). This system discharges into an existing storm sewer system in Beacon Street and then outlets into the Charles RNet. In three locations the collected runoff discharges directly from the MTL facility into the Charles River (APAP,1979). Specified 52 10/03/91 Ivrted Oh Ne# yttej Papef

s. *.

locations on the MTL system and at all of the MTL/ Beacon Street outfalls into the Charles River ars sampied and arwlyzed for water quality criteria under the EPA /Musachusetts National Pollutant Discharge Elimination System (NPDES) program. The Massachusetts Department of Environmental Protection (MADEP) is also an approving authority for surface water runoff and discharges to the Charles Rtver.

In January 1990, MTL asked the MWRA for approval to dispose of approximately 40.000 gallons of uncontamina!od water from Cistem 242 Into the MWRA sewer system This water was originally from the town water supply and was not used in any industnal processes. Disposal of this water was to be part of the site preparation prior to the decommissioning of the reactor building. In May 1990, the MWRA denied dischargo approval of the water because the disposal of

• uncontaminated non contact cooling water into the sewer system is prohlbbed" (360 CMR 10.023 (2)). Ti,orefore, this water was gradually pumpod out of the cistem and discharged to the Charles River through the existing storm drainage system.

Groundwater at MTL is not used as a drinking water source. Groundwater is located approximately 5 to 10 feet beneath the surface along the southeastern portions of the facluty and 25 to 30 feet beneath the surface along the northwestern areas. Minor variations in the direction and rate of groundwater flow in the regional hydrogeologic setting results from differences in the physical properties of the subsurface materials, but is generally toward the southeast to the Charles River. The bottom of Cistem 242, the reserve water supply tank, lies at a depth below the groundwater elevation. Water frota the cistem has been sampled and was found to have 13.0 pico curies (pCl)/L of gross beta radioactivity (USATHAMA, 1991). This actMty level was slightly above expected background activity levels. Tha water has been removed from the tank and disposed of property. There is no evidence of leakage from the cistern and no impacts are expected, l

Sanitary and industrial wastes from the MIL faciHty are discharged to the Massachusetts Water Resourcos Authority (MWRA) sewer system at severallocations (PA/SI,1988). The MWRA system d:rects the wastes to the Deer Island Treatment Plant located in Winthrop, Mass.achusetts. All Industrial wastes are treated prior to discharge, when necessary, to conform with MWRA sewer discharge permit requirements.

53 10/03/91 wwu w.o.v.,

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J 4 AIR QUALITY Air quality and omissions of air pollutants are ro0ulated under the Fudotal Cloan Air Act (CAA) and Massachusotts Air Pollutinn Control Lavs. Regionally, during 1907 in the Metropolitan Boston Air Oualpy Control Region, thoto was cne excoodance of CO, two exceodances of TSP, and two excoodances of ozone. No excoutancos for NO,, Pb, SO,, and Pf4 were recorded during 1987, the latest year for which data is availablo, in the Metropolttan Boston Region (CE,1991).

Air emissions from MTL occur from fuoi burning equipment, incineration, underground storage tanks, labortfory activ ties, and vehicular omissions The MADEP estirnatos for MTL air omicslons are presented in the Baso Closuto EIS for MTL (CE,199').

According to a report pubilshed in 1987 by the U S. Army Corps of Enginecra for AMC, MIL is in compliance with applicatWo fodoral, state, and local air pollution regulations and is inspectod annually by the MADEP (CE,1991). The U S Army Environmental Hyglone Agoney (AEHA) tocontly conducted an j Industrial radiation survey of the MTL facility (AEHA,1989). The results of this survey indicated that the depleted uranium (DU) incirwrator was operating in conformance whh U.S Army arvi fodoral regulations.

A filtration system of smoko scrubbers and high officiency particulato adsorption (HEPA) filters were in place to reduce the amount of DU omissions released into the environment. In stack monboring systerns woro in-place to monitor altborno particulato and stack sampung results indicated that concentrations of DU toloased to the environment woro below the maximum permissitWe concentrations speciflod in the federal regulations (10 CFR 90).

3 5 NOISE Noiso is regulated by fodoral, st;to, and local logislation and policles. On the national levol, nolso guidoilnes are provided by the USEPA. At the stato levol, the MADEP has published noise guidelinos based primarily on the pro existing ambiont nolso lovel (310 CMR 7,10). An increase of up to 10dBa above the ambient noiso levo! la allowed. These critoria apply at tho MTL facility property boundary. In addition, Chaptor Vill, Section 32 of the Watortown, Massachusotts Ordinances describes provisions on noise control. This ordinanco prohibits the making and creation of unnecessary noises within the town 54 10/03/01 r, - n.nma,o.n.,

, s.

limits, and further restricts the operation of construction / demolition equipment between the hours of 7 00 pm ard 7:00 am.

The reactor building itself does not produce any significant noise. For this reason, the requirement for MTL to have an installation Compatible Use Zono program has been walved by the U.S. Army Materiel Command (CE,1991). The noise-generating equipment has boon designed, constructed, ard rnalntained to minimize noise. Very few complaints have been receivuf from people living cdjacent to the facility.

5 6 ECOSYSTEMS l

161 Terrestrial Ecosystems The Charles Rrver watershod is located in the northemmos,t part of the formeriy extensivn oak chestnut forest type (Barbour et al.,1900). Since the Introduction of the chestnut blight fungus, hlchorles (Qgryg spp.) have replaced chestnuts as the toglonal codominant species with oaks (Qg.pt,qi!} r spp.),

Additionally, maplon (Am spp.) and pines (P),r,!y) spp.) are important components of this plant association.~ The vegetation at the MTL site consists mostly of ornamental plantings except for the area south of North Beacon Street which borders the Charies River. According to the Metropolitan Area Planning Council 1985 Land Use Data, agricultural areas constitute less than 5 percent of the total land area in the regional area surrounding MTL Wildlife at MTL include species adapted to urbanized areas. Mammals and birds observed at MTL are presented in the Base Closure EIS for MTL (CE,1991).

5 6 2 Aauatic Ecosvtilpmp A portion of the Charles River flows near the border of MTL, providing aquatic habitat for several wildlife species. Wettards in the Watertown area are prim:trily of two types: the forested wetland and the scrub-shrub wetland. However, there are no wetland areas at MTL A more detailed description of aquatic resources !s presented in the Base Closure EIS (CE.1991).

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No raro, throatoned or endangered species are known or expected to occur in MTL area (CE,1991). I 5 7 HISTO 11LQ2ND ARCHAEQLQGIQM RESOURCES Historic resourcos are sitos or bul!Gings of Nstorical significanco to the Town of Watortown, the Commonwealth of Massachusetts, of the nation. Archaeological resources includo artifacts assoclated with prohlstoric or historic usos of the area.

A total of 25 prohlstoric sites representing the Paloolndian through European Contact periods have boon identiflod within a three milo radius of the MTL facility. The prosonco of one known prehistoric sito at MTL, and the closo proximity of several other sitos, including the cromation burial romains, Indica'o that the MTL location was a preferred area to occupy during the prohlstoric porlod (CE,1991).

MTL, located on the western third of the original Watertown Arsenal sito, has a rich history dating as far back as 1810 and was the second oldes' crsonal in the country. The arsenal had, for over a century and-a half, carriod out a wide rango of ordnanco developments and mado numerous important contributions to tho advancement of military and civi!!an selontific Industrial technology (Dobbs,1977).

Archaeological resources at MTL are described in the Base Closure EIS (CE,1931). The Commander's Quarters (Bullding 111) has boon listed on the National Rogister of Historic Placos (NRHP). The MTL historic proporties are shown in Figure 51. In 1990, the MTL Commander, in consultation with the State Historic Preservation Officer (SHPO), declared the installation an historic district and historic aspects of the closure action are procooding on that basis.

A.fLSQQ10EQQNQhiLCS The MTL regional area, comprised of the counties of Middlesox, Suffolk, Essex, and Norfolk contains a population of 3,257,395, The birth rato of 12.22 por thousand was well below the national averago of 15.6 por thousand, and the death rate is h4gher than the nation's 8.7 por thousano at 9 6 per thousand 54 10/03/91 r.o.2,m nwee

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(CE,1991). The population breakdown for MTL as documented in the February 1990 Program Budget Guldance (PBG) is described in the Base Closure EIS (CF,1931).

Employment at MTL comprisos 0.03 percent of total employment for the region and 3.0 porcent of government employment. The Per Capita incomo in 1906 for the MTL region was $19.346, almost K000 higher than the national averago cd $14,639. MTL salaries currently total $24,013.061 (CE,1991).

S 9 WASTE DISPOSAL Uncontaminated and nontoxic wastos at MTL are collected twice a wook by a licensed contractor and disposed according to state and local laws in the Plainvillo, Massachusetts sanitary landfill. The averago annual amount of solid waste collected from MTL is approximately 6,000 cubic yards (4,650 CM). Non-hazardous metal products and paper pro transported to Fort Devena in Ayer, Mausachusetts for recycling (CE,1991).

Gecause MTL is a research facility, rather than a production facility, types of chemicals usod and quantitles of hazardous waste gor, orated vay whh current research projects. Hazardous wastos generated at MTL and disposed of during 1989 consisted of flammable solids and liquids, corrosive materials, combustible liquids, and oxidizers, as well es a number of solid and liquid hazardous substances (CE,1991).

Neutron radiography research continues to be conduct 3d on the ground level of Building 100 Research using Californium (Cf) sources and Uranium (U) is conducted at MTL This work is conducted under NRC, U.S Army, OSHA, and AMC licenses and regulations. Safety procedures for the use of these materials are in place to protect personnt.1 from radlation exposurc. Aadioactive wastos are removed from the baso and disposed of in accordance with the NRC licenses R 65, SNM 244, BML204101044 and SUB-230, and AR 38511 and AR 38540. Disposal to an NRC authorized disposal sito is arranged through AMCCOM, the Manager of the Army Radioactive Waste Disposal Program (CE,1991).

5-0 10/03/91 m.m nxt.%.,

l Management and disposal of asbestos at MTL is conducted in accordance with applicab e OSHA regu!ations (29 CFR 1910.1001) and National Emission Standards for Hazardous Air Pollutants (40 CFR 61, Subpart M). There are MTL employees certified to handle small on site tasks; larger removal is handled by certified contractors. Disposal of asbestos is through a hazardous waste contractor in crsmpilance with applicable federal and state regulations (see Section 2.3) (CE,1991).

11gJEALTH ANQ SAFETY All current uperiments in the reactor building are conducted using appropriate shielding and protection.

The facility is monitored on a regular basis and curront operations are p9rformed in accordance with procedures developed to protect potentially exposed staff (AR 38511; MTL 1990). Access to the facility is restricted through base and building security, The AEHA recently conducted a review of MTL's radiation protection and medical monitoring program (AEHA, luB9). Dased on this review MTL was found to be operating in comp' lance with the U S. Army and federal regulations. MTL personnel dosimetry results indicated that occupational exposures to lon12ing radiation were as low as reasonably achievable.

5-9 10/03/91 r~ m wan ,w.c.,

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6.0 ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND THE ALTERNATIVES This section discusres the environmental consequences of the alternativo decommissioning methods:

partial and total dismantioment. ITorim safe storage of LLW may be required as part of the partial or total dismantlement attematives (see Section 4 2). The envi onmental consequences are discussed as they relate to the ecosystem and the socioeconomic resources described in Sectioit 5.0. Impacts related to the no-action afternative are not discussed as it is not considered feasibio for the termination of the NRC license (Section 4 3). Any potential differences in potential impacts between partial and total dismantlement are noted.

61 t.ANQQ$E IMPACT _3 Under partlal dismantlemont of the reactor, no changes in land use are anticipated at the reactor facilny prior to base closure activities Total dismantlement would result in near term co weiston of the reactor building site to match the surrounding landscape and vegetation at the facility. In either case, the removal of the radicactive material and any hazardous chemicals may result in a beneficial Impacts through removal of pottntial ricks duo 10 these contaminants (10 CFR 60.82) and improved options for future lard uc.e The distribution of land use in the MTL region should remain relatively unaffected as a result of reactor building decomrnissioning. Decommissioning of the reactor building will not significantly impact the requirements for open space zoning nooded if the MTf. property '.s transferred to non-milrtary ownership.

12 WATER QMLLY IMPAG$

The docontamination and dismantlement of the reactor facility is not expected to have any impact on the existing quahty of tho nearby water resources. While it is possible that the temporary demolit!on actMties associated with dismantlement could result in temporary increases in pollutants or sediments assoclated with surface runcti, this impact would be minimized by the implementation of propor erosion contiof measures.

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The storm sewer system around Building 100 will be temporarily blockod during the decontamination and demolition operations to reduce the potontlal for the releaso of demolition sediment and radioactive surface runoff to the Charles River. The project 3rea will be surrounded with crosion control devices (o.g , haybales, sitt fence) to capture the sediment generated by the partial or total building dismantle.nent. A t. mall volume of surface runoff may be generated during the building dismantlomont from dust suppression activities. This surface runoff from the building dismantioment will be collected and field monitored for radiological and chemical contamination. Water that must be drummod, due to potential contamination, WWI be sampled according to EPA regulatory guidelinos for contaminant levels to determine the ultimate 'llsposition of the water. Samplos will be analyzod for parameters such as the Target Compound List (TCL) analytes, Target Analyte Lt" (TAL) metals and gross alpha and gross bota-omitting nuclides. Surface water exceeding regulatory contamination entoria WWI be drummod ard dispot.ad of property, and uncontaminated water meeting 10 CFR 20.203 critoria will either be pumpod to a downgradient storm sewer structure and dischargod to the Charlos River or will be dischargod directly to the sanitary sewer system (EG&G,1991a). Discharge methods will be approved by the MADEP, MWRA and HQ AMCCOM prior to their implomontation.

Total dismantlemont of Building 100's basement may require tomoorary dewatoring of the excavation area. The dowatering operation may be conducted by the installation of pumping wells around the building foundation or the use of pumps in the excavation trench area. The extracted groundwater will <

be collected and floid ter,tod for both radiological and chemical contaminants. Po,. ding the results of the field analysos, uncontaminated groundwater will be discharged downgradient of the project area into the storm sewer system, outletting to the Charios River. Groundwater excooding regulatory criteria will be disposed of by a licensed hazardous waste contractor, according to U.S. Army, fodoral, state, and locel regulations. Discharge of the ecacted groundwater to the Charles River via the storm sewer system will be temporary and is not expec'od to cause any public health or environmental impact.

Sanitary wastewater flows from MTL may temporarily increase during the decommissioning operation due to the additional construction personnel on-site. Once the facility decontamination and dismanttement operations have boon completed, the quantity of sanitary wastewater flows will rotum to existing corxiltions or decrease, depording on the possible relocation of MTL operations.

6-2 10/03/91 Prmted on Rc;yckd Par yt

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6 3 AIR OQAJJIY lMPACTS None of the emissions associated with sources at MTL hevo been dolormined to significantly degrado air qt.ality at MTL or cause the air quality of the reglon to excood the national er state ambient air quality standards. More importantly, no omissions are or will be generated from the reactor facility itself.

A temporary controlled increase in dust om!ssions may result during demohtlon activities associated with olther total or partial dismantlement. Appropriate dust suppression practicos will be employed during demoittion to mitigate impacts. Those practicos may include water spray on buildings and btructures and the application of chemical dust suppressants.

Specific concoms with potential temporary air quality impacts, from the removal of radioactive contaminated material, are mitigated through the NRC approval of the Decommissioning Plan. NRC critoria for decontaminating the facility alsu incorporate USEPA guidelines Tho safe removal of the radioactive material will be conducted by tiealing off the proposed work steas, based on the results of the radiological survey, and health and safety plan. The reactor budding will then provide a secondary containment for the protection of the surrounding public and environment, untp the radioactive material from within the facility has boon removed and securoly drutnmod. Ventilation exhaust from the reactor building to the environment will be filtered for particulate material. These HEPA filters WM be maintained throughout the ronioval of radioactive components and asbestos material and intomal building demolition. The exhaust ducts will automatically close in the event of failure of the ventilation unit.

fladiation monitoring will bo provided on the exhaust air by which the exhaust fans will turn off if prescrit*1 health and safety limits are exceodod. Thereforo, air quality impacts from the dismantlement operations are expected to be minimal.

6 4 NOISE IMPACl$

Temporary and localized increases in noise lovels will occt*f during the dismantlement of the reactor whether it be total or partial dismantlement. Designs and specifications for dismantling the reactor facility will be required to minimize noise and vibrations to provent interruptions to sensitive equipment and experiments in other buildings at MTL. Potentially, a moderate increase in noise may result in tho r

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s short term dlbturbance of the surrounding residential area adjacent to MTL if necessary, schedulod fostrictions on demolition and truck transportation actMtles would serve to mitigato noise impact to the surrounding nolghborhoods.

6 5 ECOSYSJ1M IMPACT)

No endangerod of threatened spoeles of plants or animals are recorded at MTL MTL is approximately 85 percent pavod with asphalt or concrete. As a result, the natural habitat is reduced to grass and the Spocles noted in the Base Closuro EIS (CE,1991). The lack of donso veget.ition for food arx1 dwelling space and the constant urban activities provide a poor habitat for wildlife. However, grassed areas will be returnod upon cornpletion of the decommissioning onorations and care shall be taken to protect and tavo existing trees or shrubbery, if possible. Total dismantlement will increase the land area for the potontial increase in diverse native flora and fauna.

Ongoing activities associated with the reactor have little, if any, impact on the terrestrial or aquatic environment. Erosion due to dismantlement of the reactor building will be controlled by crosion control techniques to avoid any impact to the aquatic environment. These erosion control measures are presented in Section 6 2.

1.6 HISTQRICAL AND ARCHAfiQ(QGICAL lMPACTS Consultation with the Massachusetts Stato Historic Preservation Office (SHPO) has been initiated by the U.S. Army to identify requiroments for the dismantlement of the reactor building. The Horace Hardy Lester Nuclear Research Beactor is eligible under Criteria D for listing in the NRHP as a coritributing element in the Watertown Arsena! Historic District. The Massachusetts Historical Commission (MHC) has determined (see letter from B. Simon, MHO to L nodman, MTL dated October 1990 in Appendix C) that the proposed removal of the reactor facility will have no adverso effect (36 CFR 800.9(c)(1))

provided that the following conditions are met:

e the condition of the reactor facility is recorded according to the Historic American Building Survey / Historic American Engineering Survey (HABS/HAES) documentation standards 6-4 10/03/91 n,-.-u n mr.,

% *e e copios of the documentation are submhted to the National Park Service for transmittal to the Library of Congress and to the MHC for transmittal to the Massachusetts State Archives This decision is based on the consideration that the reactor faculty and existing equipment may represent a hazard to public health and safety and the fact that the U S. Army is under a time constraint to complete removal of the f acility before the January 1,1993 federal moratorium on the disposal of LLW.

Prior to decommissioning the reactor faculty by either total or partial dismantlemont, artifacts whh historical significance WHI be preserved. These artifacts have boon identified and includo items such as the scalo model of the reactor, the dodication plaque, photographs of the construction and operations, operating logbooks, and parts ci the control room. Those artifacts will be maintainod at MTL or at an atteml:te suitable sito after closure.

Partial dismantlement would have no adverse impact en the control room artifacts and items associated with it. Excavation of the basement and foundation during total dismantlement could result in the dir.covery of additional artifacts. Proper procodutos will be followed if artifacts are discovorod (36 CFR 800 9 (c)(1)).

A.L.SQCIOECONOMIC lMPACTS Partial dismantlement of the roactor faculty wHi have minimal socioeconomic impact on the MTL facility and surrounding communities. Although there is a short-term displacement associated with both total dismantlemont and partial dismantlement, theso lobs wHi ultimately be displaced with the closing of the installation. Partial dismantlement may have a greator short term impact on the reactor facility staff due to the staff relocation during the decommissioning operation hnd then the second relocation back into the reactor fac!!Ity. Total dismantlement will require more substantial demolition activhies, but wHl result in minimal short term socioeconomic impacts on the surrounding community. The radiography research could be permanently relocated to other on, or off site facuities and a small number of employees would have to be relocated. Temporary increases in construction personnel and equipment needs for the decommission'ng activities may offset those short term socioeconomic !mpacts on the surrounding 6-5 10/03/01 Printed on Recyded Papst

- - - .__-i

o' ,e community. The research roactor has been inoperable for approximately 20 years ard wlit have no significant impact on the past equipment access pro'/ided collegou and unkersities. Total dismantlement of the roactor faculty may further provido a positive sociooconomic impact as part of the potential development of the MTL base, resulting from tho base closure.

Base closuro WWI have the greatest impact on the socicoconomics of the facility ard surrourvjing community. This will be causod by the reiocation ard olimination of current jobs at the base and reduction in monios spent at nolghboring businesses. These impacts have boon ovaluated in the Final Environmental Impact Statomont (CE.1991) prepared for the site ard determined that this loss represented loss than one porcent of both the population and incomo for the region, and woro not signtricant. The Dopartment of Dofonse would further assist displaced personnel in firding now positions with the fodoral govemmont.

$ 8 WASJg_Ql$fQ}AL IMPACTS Regardless of which decoramissioning attemativo le selectod, all environmental contamination capable of migrating from the installation boundarlos will be treated or coritrollod to protect public hoalth ard the

, en/ironment. The types and quantitles of wawes gonorated by the reactor facility docommissioning are presented in Section 3.1 of this EA.

Under the terms of the federal LLW mandate, the Commonwealth of Massachusetts is responsible for the proper disposal of LLW gonorated within Massachusetts (Sectici,3.1). The mandate requires states to establish and oporato a disposal faciWy within their boundarlos or form a compact w!!h another stato(s)

! for the purpose of LLW disposal. The establishment of a disposal faci!!ty must be accomplished within a milestone schedulo (Table 31); failure to moot this schedule results in 41nancial surchargos on the out of-state LLW disposal and subsequent access dental to the eMstin{, out c0stato disposal sites.

Because of the federal LLW mandate and rnilostono schodule, al! LLW must be romcved from MTL and property disposed of prior to January 1,1993, if possible. Dolays in the proposed docontarnination unti 1 after this date would result in the need for Interim safe storage of any romalning LLW on-site or at another Massachusetts site until this issue is resolvod. This contingoney, in the caso of total l

l 4

l 64 10/03/91 nm,wnm.,

2 __ _ _ _ . n- ._

dismantlement, would require adherence to appropriate regulations and using additional security to limit access (Section 4 3). Decommissioning of the reactor facility will tempo.ority increase the volume of waste generated at the post, however, ongoing disposal practices will not bo impacted.

Liquid radioactNo wastes may be generated during the decontamination of the reactor facihty. The possible sources of the liquid radioactive waste are: decontamination of compononts, structures and floors; personnel decontamination liquids; and resdual liquid in piping and otaer components. This waste will be collected, monttored and released to the sanitary sewer system only if the wastes satisfy 10 CFR 20.303 and other federal and state permit requirements (e g , NPDES). Otherwise the water will be treated to removo contamination or disposed of as LLW. Procedures for disposing of the liqW radioactive wastes will require approval from the U.S. Army HO AMC and will comply with all applicable federal, state and local regulations. Further details of the troatment and disposal methods are presenttd in the Decommissioning Plan to be approved by the NRC.

3.2.1.MLTH AND SAFETY lMPACTS The primary health and safety concerns to workers and the public are related to the potential exposure to radioactive material during the decontamination and dismantlement of the roactor facility, and the transportation of the radioactivo material to the disposal site. Issues related to the suspension of dust particles are addressed in the Decommissioning Plan (EG&G,1991a). A diaton protection program will be prepared by the decommissioning contractor and will bo be.sou o.: MTL's existing radiation pogram, MTL-M 3851-1 (CE,1987) Transportation issues will be addressed by conforming to NRC, DOT and individual state packaging and transportation regulations.

Radiation exposure from tho decontamination and dismantlement of the reactor facility will be accomplishod in accordance with NRC regulation 10 CFR 20. This regulation specified the maximum exposure limit to individuals of the public (not site workers) whole body to be 0.5 rern/yoar (10 CFR 20105, revision 1/1/90). This regulation was recently revised (Federal Register 5/21/91) to limit the public indMduals' whole body exposure to 0.1 rem / year. The NRC and AMC have an agreement that this new regulation will be Implemented on January 1,1993 (Apperidix D). The anticipated exposure 6-7 10/03/91 nm,,o ne,a,ow ,,

.' .s levels to the gonoral public after the reactor facility has boon decontaminated and dismantled will be equivalent to that of naturally occurring bat.kground radiation.

In the case of occupational exposurn,10 CFR 20.1(c) requires that aoplication of *as low as reasonablo achievatwe* (ALARA) principle to aontrol radiation exposures EG&G l as estimated the doso to workers based on estimatos of task duration, crew slzo and average radiation fidds, The estimated radiation dose for each task is present A in Table 61 and results in a total 1stimated exposure of 10 man-tems for all of the decontamination tasks (EG&G,19b 'a). Actual radiation dosos to per.,onnel will be kept to ALARA by the contractor establishing work procodures and a radiation / hazardous work permit system.

Personnel 18 years of age or older and classiflod as radiation workers will be monitored and controlled according to the administratNo guidoline ana radiation dosos presented in TatJe 6 2. Whole bcdy dose limits for working personnot may exceed those listed in Table 6 2 If the radiological control and safety officer has provided the contractor with writton authorization; however, the maximum occupational radiatlon doses, presented in Table 6-3 and based on 10 CFR 20.103, will never be excooded. If visitors and non-classiflod radiation workers require access, exposun 'ill be maintained below the dosos prosented in Table 6-2. Chapter 2 of the Decommissioning Plan (EG&G,1991a) provides a more detailed description of the radiation dose exposuro limits, the work permits, and the engineering controls.

Decontamination followed by total or partlal dismantlement will renutt in the generation of Low Specific ActNity (LSA) radioactNe matorials that will be transported to low levol wasto disposal facilities (See Section 3.0). The health risk to workers and the public from the transportation of radioactNo matodal has been addressed in the development of recommendations for packaging and transporting such materials. The development of these recommendations is based on NRC perfonnance critoria (NRC, 1977) of the containers which provide a set of engineering test specifications, rather than specific container design requirements. To define the actNity limits for LSA materials, the IAEA estimated, based on radiotoxicity, that LSA materials are ' inherently safe' (NRC,1977).

EG&G estimatos that most of the radioactNo wastes generated by decontaminating the MTL reactor fac!'Ity will be claolfiod as Class A unstable wasto (EG&G,1991a). Class A wastos contain the lowest amount of radioactivity of the three LLW classifications (A through C).

6-0 10/03/91 m m neau.o.m

t T

, i TABLE 5-1 i ESTIMATED RADIATION DOSE FOR DECOMMISSIONING OF TrtE MTL REACTOR FACIUTY i i

lt ESTIMATED AVERAGE  !

TASK DESCRIPTION - l TASK DURATION (hr) ESTIMATED CREW SIZE RAD"ATION FIELD (rem /hr) MAN-REMS j j Remove components from reactor annulus 2 3 18 0.1 i '

, e Remove reactor pedestal and associated hardware 35 4 10 1.4 i I

t

Remove reactor vesse stainless-steel liner 20 4 5 0.4 '

Remove beat exdergi-s, pping, and demineralizers 34 6 2 0.4 i l

Remove reactor inner concrete shield 84 to 4 3.4 l t

Remove reactor high densky come sheid 156 10 2 3.1 l a

i Remove reactor outer concrete sheeld 32 10 1 0.3 1 i

Remove reactor vessel base in bcsement 88 10 1 0.9

{ TOTAL MAN-REMS 10.0 L

}

i l REF: EGSG,199f a i

f 4

h I

l l 1 6 l

i  !

i I

l i

i I

h

. - . . . _ - - ~ . _ - - . - - . . . - . - . - - . - _ _ . . . - ., _ ._. _ .__~. . ~

.e .t 2

TABLE 6-2 ADMINISTRATIVE GUIDEUNES FOR RADIATION WHOLE BODY DOSES DURING DECOMMISSIONING i

ADMINISTRATIVE GUIDELINES (mrom)

NONRADIATION WORKERS AND VISITORS - RADIATION WORKERS Houriy 0.2 -

Daily 2 100  ;

Weekly 10 300 ,

Catandar Quarter 13 500 Calandar Year 50 1,000 mrem = 1x103 rem Rof: EG&G,1991a.

TABLE 6-3 REGULATORY UMITS FOR RADIATION DOSES DURING DECOMMISSIONING FOR A CALENDAR QUARTER (mrom)

REGULATORY UMITS FOR RADIATION WORKERS * (mrom)

• Whole Body, Gonads, Blood-Forming Organs, Lens of Eye 1,250 ,

Hands and Forearms, Feet and Ankles 18,750 t Skin of the Whole Body 7,500

. _' wul be utHtzed unti January 1993.In accordance with an agreement with the NR Imrem = 1x108 rem Ref: EG&G,1991a. '

1 6-10

!. _ . . . - . ~ -. - -. - - - - - -- - - - -

- - - _ _ . _ , _ - ~ . - - - - - . - - . . - _ _ . , - - - _ - - - . . - . . .

-s, s.

The NRC has conducted detailed analytical assesstnents on the transportation of radionuclides in urt~an I environments (NRC.1900). These assessments involve several population exposure pathways, drfferent causative events and altomatives to current transport practic9s that contribute to environmental and l

Social impacts. Because the number of past transportation incidents !S small and the consequences slight, the assessmbot Indicated relatively low environmental risks were associated with thn I transportation of radionuclides. Additional studios have been cowfucM by the NRC on the radiation doses from postil'ated transportation accidents. NUREG/CR 1750 (NRC.1987) analyrod two accident  !

situations involving combustible radioactive wastes in Pype A packages. The .g.oro transportation ,

accident assumed to involvo the rupture and fire of forty 55-gallon containers of LLW. The minor  !

accident involved only one 55 gallon container of LtW. Both of those accident situations have a low l

frequency of occurrence and result in a range of whole body (first year) radiaticq dose of 3 2 x 10' to l 1.3 x 10' roms. These values are well below the NRC regulatory exposure lim"s for an Individual of the j i

public (0.5 rem / year,10 CFR 20.105) and a classiflod occupational radiation worker (1.0 rem /yoar, Table i

62). '

Compilance with both NRC and DOT packaging and transportation requirements should onsure that I there would be no significant adverse impact resulting from the transportation of the materia's produced l In either partial or total dismantlement. In the rare occurrence of a transportation accident involving LLW, the Federal Emergency Management Agency, in cooperation whh elevon other agencies, will Implement an existing emergency responso plan. Further, removal of the LLW from the site will reduce potential risk to public health and the environment.

Hoatth and safety impacts from the interim safe sto age of the LLW, potentially part u 41 or partial dismantlement, will be controlled through the mair'tenance of the storage operation and implomontation I of a monitoring program. The sealed containers of LLW will be inventoriod, locked and secured at an NRC approved facility. Those containers will then be rnonttored for any leaka00 of radioactivity, based on an NRC approved schedule (Section 4 3).

In the event of an emergency during decommissioning, a disaster control plan (MTL,1987) will be available to guide responso measures. The plan includes procedures, resources, and coordination measures necessary to direct recovery actions, An agreement between MTL and the Town of 6 11 10/03/91

(

V r-a w ,,,,o.w

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l

)

1 l

Watertown providing firefighting services to the facility will aiso be enacted (MTL,1991). The contractor shall implement fire provention measures and make available portaldo type A and B/C fire extingulshers i on site during the docontamination and dismantlement operations. (EG&G,1991a),

t 6.10

SUMMARY

OF lyPACTS AND ASSOCIATED MITIGATION FACTORS A summary table presenting adverse and positivo impacts caused by decontamination and total or partial dismantlement with potentlai mitigation measures is presented in Table 04 Temporary adverso impacts to water quality, air quality, noise and ecosystem can be mitigalod by applying appropriato control measures to reduce crosion potential, dust emissions, or by scheduling to comply whh local noise ordinances. Potential long term bonolits are anticipated by sale romcval of low lovel radioactNe waste at potentially hazardous inatorials, ano opening the area for unrestricted use. Historical trssources will be preserved as appropriate and there is the potsntial for discovery of historical artifacts during total dismantlement by exposing the subsurface soils beneath the reactor facility. Socioeconomic

.mpacts ars related to short-term situations, Long term impacts will be trelated to the overall base closure, which are discussed in the EIS prepared by the U S Arrny (CE,1991).

6 12 10/03/i,1 F#inted on f4etyded Paper

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s, *. 7.0 LIST OF AGENCIES OR PERSONS CONSULTED Brownina Ferris Industries Mr. Michael Quatromani Regional Environmental Comp!ianca Envirocare of Utah. fr.c. Mr. Kurt Higgins Marketing Department Massachusgas Dooartment qf.,,5.nfrgy no name Massa.phusetts Degament of Environmental Manaasmet Mr. Joe Paluzzi Safe Waste Management Pf4spachusetttOenartment of Environmental Protection Mr. r1 erb Redman Boston Massachusetts Massachusetts Deoartment of Public Health Mr. Robert Hallisey Radiation Control Program, Director Mr. Gus Savanstano Radiation Control Program Mr. P.obert Watkins Radiation Co.. trol Program Massachusejts Deoartmant of Public Wcrks Mr. Joseph McCarthy Permitting DNision Massachusetts Department 9f PuMj.gAfgy Fire Marshall's Otfice Jack F%ney inspection DMsion 7-1 10/03/91 Ef10ted D% MCyCled Paper I

s ..' ,, I LAMSathuittiLQpgartmenj of Transpodating Ms. Tia Wana Massachuttili. Low Level RadioactNe Waste Manaaement Board Ms. Carol Amick Waste Management Board, Director Mrs Sheila Holmes Waste danagement Board

         . Massachusetts Metrooolit:"' Qipric' Qomma m Mr. Ed Anders                                                    MDC, Parks Engineering & Construction Division Mr. John Mace                                                    MDC, Permit DMsion N,gglear Reautatorv Commission Mr. Al Adams                                                     Washington, D.C.

Mr. Thomas Dragoun King of Prussla. Pennsylvania Mr. Jerry Roth King of Prussia, PennsylvanL1 Nuclear Regulatory Document Room Town of Watertown. Massachusetts Mr. Joe DMco Board of He* Irectar Mr. Mark Hayes Department c r;olic Works Ms. Kathleen Buscatto Conservation Coramission Mrs, Nancy Sec:t Zoning Enforcemern Officer Mr. John Detoma Buiiding Inspector ir.cpector Stems Fire Prevention Bureau

1) S. Anny_Qsmtpf Enaineers. Huntsville DMsiso Mr. John Romeo Huntsville, Alabama

          ,llS Army Coros of Enaineers. New En_ gland Division Ms. Susan Brown                                                 Waltham, Massachusetts 7-2                            10/03/91 Prime d on >4cycied Farer

s.- $. ) 1 U.S. Army Matericl9 Technoloav Laboratory Dr John Antal Reactor Supervisor Mr. Robert Chase Chief, Hazards Management and Safety Officer Mr. Peter Cornetta Radiation Protection Officer Mr. Samuel Gilfix Environmental Manager Ms. Laura Rodman Base Realignment and Closure Officer ILS Army Toxic and Hazardous Materials Aaency Ms. Phyllis Breland USATHAMA Mr. Mark Mahoney USATHAMA U S. Deoartment of Enerav Mr. Day Boston. Massachusetts Mrs. Kristie Lowe Washington D.C. Mr. Bill Wisenbacker Waehington D.C. l 1).S. Environmental Protaction Aaency l l Mr. Philip Cutler Asbestos Inspector l l U.S Deoartment of Transoortation Ms. Lucy Johnson Regulations 11tah Deoartment of Health. Bureau of Radiation Oontrol Mr. David Finerfrock Salt Lake City - 1-l 7-3 10/03/91 Df10t?d On AeCyCMd Esper

s, %. l l l

8.0 CONCLUSION

S The preceding chapters describe, compare, and evaluate the potential environmental cost, and schedule impacts of the attematives for decommissioning the reactor facility at MTL. Based on a preliminary screening of alternatives, only partial and total dismantlement were evaluated in detail in this report. Other alternatNes - safe storage, entombment and no action were deemed unacceptable because they do not meet NRC requirements for terminating the possession-only license, R 65 (10 CFR 50.2 and 50.82; NRC,1974). Additionally, these alternatives would delay the schedulod base closure of MTL and would be impacted by the federal Lt.W mardato for out-of state LLW disposal by January 1,1993. Coniparing the partial and total dismantlement attematives using cost, schedule and environmental, and safety criteria indicates that the two alternatNes are nearly equal (Table 8-1). Partial dismantlement has a lower estimated decommissioning cost than total dismantlement. The release of the facility for unrastricted use is required by NRC to terminate the R 65 license. The displacement of on-going research actNitles by total dismantlement will be a short term impact. The current research activities could be temporarily relocated to another location on-site, pending NRC approval, alleviating the impacts. Partial dismantlement will create a greater short-term impact due to the sta'f and equipment potentially being relocated twice in a relatively short time period. The first relocailon will be for the decommissioning of the facility; the soc" id relocation would return Ine research actMiles to Building 100. Potential land use opportunities and improvements to the ecosystems are long-term positive impacts from dismantlement. Increase open space, caused by the total dismantlement of the reactor facility and future reuse of the site after the propert -'3 transferred from the Army, may prov'de habitat for the local flora and fauna. The enviror. mental effects of the total and partla! dismantlement alternatNes were evaluated comparatNely. The impact rnatrix (Table 8-2) summar!zes the relative short-term and long-term acverse effects and benefits of these alternatives. No moderate long-term decreases in quality were projected for either afternative, except for total dismantlement's imcacts on historic resou ces. This moderate 8-1 10/CJ/91 Ptiote 3 cn Recried kuper

      , . - .                         .       . .    . - - - . . . _ . . - . . -                 -..--     .-~.               .        ..--- -,                                 -._
                                                                                                                                                                  . e               , o 1

l TABLE 81 i l

SUMMARY

COMPARISON OF THE l TOTAL AND PARTIAL DECOMMISSIONING ALTERNATIVES , l DECONTAMINATION AND DECONTAMINATION AND i

                    . EVALUATION CRITERIA                           TOTAL DISMANTLEMENT                      PARTIAL DISMANTLEMENT--

Estimated Decommissioning Cost'*  ; 6.1 million S ' ' ~ 31 *I!IIU"

Potential Impacts to Existing Schedules' MODERATE MODERATE Potential impact to the Environmenf LOW LOW

                    - Regulatory involvement                                MODERATE                        MODERATE Extent of Post Decomm'ssion                                                                                                                                         -
                  - Investigations                                          MODERATE                        HIGP L Displacement of Ongoing Research Activities                                   PERMANENT-                      TEMPORARY (26 weeks)'-

NOTES: L -' Based on EG&G,1991a

                              . Does not include cost of asbestos removal or final charactorization survey -

a Potential schedule impacts are related to the federal LLW rnandate restricting out-of-state !. ' disposal after January 1,1993 and the September 1995 base closure of MTL. L A'ssumes compilance with all eppropriate regulatory requirements. 5 l Base closure schedulod for 1995 will permanenti, "splace all research actMtles at MTL 3 I l 82-eu

• P'- +- v- Ws' + y&-wr"w- 4Jy1- w V p .-n iy 9 t- T- w 1 '-- 9mMrr "*=miT9J w

                                                                                                                                                            **9tt   g g y =W==-nfr      v

                      . - . . - _          . ~.                   . - ~                 . . . . . ~ . - . .         . .    - _.-_.. - ~.. -                                    -           .               . ..
    , >w    %

2 TABLE 8-2 COMPARISON OF SUBJECTIVE ESTIMATES OF IMPACTS T DURING AND AFTER DECOMMISSIONING OF THE MTL REACTOR FACILITY WATERTOWN, MASSACHUSETTS

                                                                                                                        > Alternatives Environmental

• Attributes DECONTAMINATION AND - - DECONTAMINATION AND No Action P.ARTIAL DISMANTLEMENT t

TOTAL DISMANTLEMENT During - After During After Physical Environment

                  -(Soils)          ,

0 1 0 -1 - +2 Land Use : 0 1 0 1 +2 Water Qua;;ty 0 1 0- 2 +1 Air Quality 0 1 0 -2 -+1 Noise 0 1 0 -2 NE Ecosystems 0 1- 0 1 +1-Hittoric Resources

• O- +1 1 -1 -2 Archaeological Resources - 0 -0 0 +1 0 Socioeconomic 0 -+1 NE +1 NE Radiological Conditions 0 -1 +1 1 +1' 0= no change 1= small decrease in quality

               -2 = moderate decrease in quality -
               +1 - ~ small increase in quality
              +2 = moderate increass in quality-

• A survey is required. ' Mitigation may be required under the Cultural Resources Act.

NE - Not evaluated. Will be based on future use of MTL i l t 8-3 i j .-

         ,.                                - . . - . . . ,     - - . , . , , . . - - --                     , . - .         .,-,a.          ...,,,,,,.,,n.,          ..e,-~.-. e..<,...,..n,,.-c.,.,--..

                                                                                                                                      .     , e decrease in quality is related te the loss of the reactor facility, however, this will be mit! gated by the presarvation and documentation of s>cific control room equipment, photographs, operating records and any other artifacts identiflod and preserved prior to the initiation of decommissioning. Partial dismantlement would resbit in less of a decrease in qua!!ry over the short-term (particularly to air, noise, and water quality) due to the reduced scale of operation, but would provide fewer long term environmental and local cornmunity benefits. These short-term decreases in quality would be rJated to sediment in surface water runoff, groundwater quality, air quality due to dust, and nolso quality due to the decontamination and demolition of concreto and steel. Total dismantlement, while exhibiting a                                    ,

slightly higher level of short term adverse impacts, would provide a groater increase in environmental- < quality upon the completion of the decommissioning operations. The anticipatod increases in quality occur in the physical environment, in opportunities of future re-use of the site by the public (property available for unrestricted use), and in incroased land area for local flora and fauna. Additionally, total dismantlemoet would a!!ow the U.S. Army to transfer the property without the building on the site, as desired by the majority of the town and local community. Long term socioeconom'c impacts were not evaluated due to the uncertainty regarding future reuse of MTL Interim safe storage. on-site or at another licensed facility within Massachusetts, may be a necessary contingency for either partial or total dismantlemer.t if Massachusetts does not comply wbh the federally-mandated schedule (Figure 3-1), Facilitlos for interim safe storage could be temporarily constructed at ML Interim safe storage would require either, (1) a modification of the existing NRC license (SUB 238) for storage, or (2) permission from NRC for storage concurrently with their approval of the Decommissioning Plan. The appilcation of NRC and U.S. Army approved storage and monitoring methods would result in no significant risk to public health and the environmont. -Interim safe storage

             'would be used until acces: to a disposal site in- or out of stato is granted. Ultimately, the !.LW must be property removed from MTL by 1995, in accordance with the U.S. Army's base closure scheduto as mandated by federal . law.

E in summary, to comply with the requirements to terminate the NRC possession-only license (R 65) and

            . to proceed with decommissioning, MTL is proposing decontamination and total chsmantlemont of the reactor facility. The few long term and short-term impacts caused by this proposed action will be addressed by the iroplementation of mltigation measures. Further, total dismantioment will eliminato any 8-4                                               10/03/91 RWed en Recyded Paper a
                        -                -       _        ,     _                     -_,- . - - - , -     .,-, ,-   ,.,m  ,m,    _ ,     _m,     ,

potential health risk concerns that the public may have with partial dismantlement and provide long-term benefits by allowing the greatest flexibility for future land use This EA concludes that the decommissioning of the MTL reactor facility is not a major action significantly affecting the environment. The proposed action also does not affect the environmental impacts or change the conclusions of the facility's base closure EIS (CE,1991). Therefore, a supplement to the MTL's EIS is not required (40 CFR 1502 9). 8 -5 10/03/91 Evted on Recyr.ied Paper

          .- - _ _ .                _ . . . _   -     _ _ _ _        _ ~ - _ _ . _ . _ . _ _              . - _ _ _ . _ _ - . _ _ _ _

q. '.

9.0 REFERENCES

AEHA,1989. Industrial Radiation Survey No. 27-43-0401-90 prepared by United States Army Environmental Hygiene Agency, April,1989. AMMRC,1970.- Army Materials and Mechanics Research Center. Deactivation Report of the Army l Research Reactor, December 1970. l ANS,1981, American National Standards for Decommissioning of Research Reactors, American Nuclear

                            ' Society, ANSI /ANS - 15 10 - 1981, l

APAP' 1979. Army Pollution Abatement Program. New England Area, investigation of Storm Drain Pollutants at the Army Materials and Mechanics Research Center, Watertown, Massachusetts, i prepared for Department of the Army, New York District Corps of Engineers, by Coffin & 1 Richardso,1, Inc., July 1979. l Barbour, M.G., J.H. Bork, and W.D. Pitts,1980. Terrestrial Plant Ecolo.gy. The Benjamin /Cummings  ; Publishing Company, Inc. Menlo Park, CA. 604 pp.  ! CE,1984. *Charies River Natural Valley Storage Project Master Plan for Recreation Resources Development, Design Memorandum No. 4, Waltham, Massachusetts. l CE,1987.- Safety arx! H0alth Requirements Manual EM 3851 1, Department of the Army, CE, April, 1989, CE,1991, ' Final Environmental Impact Statement for the Army Materials Technology Laboratory Closure with Transfers to: Detroit Arsenal, Michigan; Picatinny Arsenal, New Jersey, Fort Belvoir,

                           . Virginia" Prepared by the Department of the Army. Corps of Engineers, New England DMsion:

August 199? DEOE,1987. Air Quality Standards for the State of Massachusetts,1987,- Dobbsi1977, 'A History of the Watertown Arsenal, 1816-1967' U.S. Army Materials Mechanics Research , Center, Arsenal Street,74 pp. DOH. " Asbestos Policy and Procedure Mant.al, Guidelines for Management and Maintenance Per onnel.': Massachusetts DMuon of Occupational Hygiene, Asbestos Program,1001 Watertown Stroet, West Newton, MA 02165. EG&G,1988. "Prellml.1ary Assessment / Site Inspection for the U.S. Army Materials Laboratory"; Aberdeen Proving Ground. Prepared by EG&G National Engineering Laboratory, Idaho Falls, Idaha. - 91 10/03/91 Printed on Ncycled Paper

 , n. n-       -  .-,.,n,,        -

                                                                                                      .<*   ,o EG&G,1990a. *Charactorization Report for U.S. Army Materials Technology Laboratory Research Reactor *; Prepared by EG&G Idaho, Inc. for the United States A*my Todc and Hazardous Materials Agoney, Base Closure DMslon under DOE Contract No. DE AC07-761DO1570.

EG&G,1990b.

• Decision Analysis Report for U.S. Army Materials Technology Laboratory Research Reactor *; Prepared by EG&G Idaho. Inc. for the United States Army Toxic and Hazardous Materials Agency, Base Closure DMsion under DOE Contract No. DE AC07 761D01570.

EG&G,1991a. Decommissioning Plan for U.S. Army Materials Technology Laboratory Research Reactor, prepared by EG&G Idaho. Inc. 'or the United States Army Toxic and Hazardous Materials Agency, Base Closure DMslon, under DOE Contract No. DE ACO7 761001570, September,1991. EG&G,1991b. Demolition and Reclamation Plan for Building 100 at the U.S. Army Materla!s Technology Laboratory at Watertown. Massachusetts, prepared by EG&G Idaho, Inc. for the United States Army Toxic and Hazardous Materials Agency , Base Closure DMslon, under DOE Contract No. OE AC07 761D01570, September,1991. MA LLW,1990 ' Annual Report of the Massachusetts Low Level Radioactive Waste Management Board

• Publicction No. 16, 525-396-35011-90 CR, November 21,1990.

MTL,1987. Army Materials Technology Laboratory Disaster Control Plan, Department of the Army, Materials Technology Laboratory, Watertown, MA., Juno 1,1987. MTL,1FJ0. MTL - Memorandum No. 385-4. Depaitment of the Army, Materials Technology Laboratory, Watertown, MA., June 30,1990. MTL,1991. Memorandum of Agreement between U.S. Army Materials Technciogy Laboratory and the Town of Watortown, Massachusetts, January 25,1991. NRC,1974. U.S. Atomic Enorgy Commissic.) Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors. June 1974. NRC,1977. Final Environmental Impact Statement on the Transportation of Radioactko Materials by Air and Other Modes. NUREG 0170 Volume 1. December 1977. NRC,1980. Transportation of Radionuclides in Urban Environs: Draft Environmental Assessment, prepared for U.S. Nuclear Regulatory Commission Transportation and Products Standards Branch, prepared by Sand!a National Laboratories, NUREG/CR 0743, July,1980. NRC,1984. Guidance and Discussion of Requirements for an Application to Terminate a Non Power Facility Operating Ucense (Rev.1). Prepared by Standardization and Special Projects Branch, dMslon of Uconsing Office of Nuclear Reactor Regulation, U.S. NRC, September 15,1984. NRC,1987. Guidol!nes for Decontamination of Facilitios and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Spec!al Nucioar Material. U S. Nuclear Regulatory Commission, DMslon of Industrial and Medical Nuclear Safety, August,1987. 9-2 10/03/91 Prtnted on Recycled Paper

 $. s.

PA/SI,1988. Preliminary Assenment/ Site Inspection for the U.S. Army Materials Technology Laboratory Prepared for U.S. Army Toxic and Hazardous Materials Agency, by EG&G idaho, Inc., March, 1988. PE,1991 Asbestos: A Regulatory Issue in 1991., Pollution Engineering. May,1991. Skehan,1979. "Puddingstone, Drumlins, and Ancient Volcanor, Westone Press, Dedham, Massachusetts. TRC,1990. Asbestos Building Assessments, U.S. Army Materials Technology Laboratory, Watertown, Massachusetts, prepared by TRC Environmentsi Consultants, Inc., May,1990. U.S. Army Corps of Engineers, See CE USATHAMA,1988. Geotechnical Report Army Materials Technology Laboratory, Watertown, Massachusetts, preparg by Arthur D. Little. Inc., for the United States Army Toxic and Hazardous Materials Agducy and EG&G ldaho, Inc., August,1988. USATHAMA,1991. Draft Final Phase I Remedial Investigation Report, Army Materials Technology Laboratory, prepared by Roy F. Weston, Inc., for the United States Army Toxic and Hazardous Materials Agency, Base Closure Olvision, Apr!!,1991. Zen, E. An, ed.,1983. Bedrock Geologic Map of Massachusetts. Zoning,1990. " Zoning Ordinance *, Watertown Planning Board, Watertown, Msssachusetts. Prepared by the Department of Community Development and Planning, November,1990. I l l l 9-3 10/03/91 W.nted c6 Recyded Paper I

          - - . . ~ . . - . . . . . .             ~ _ . . . .       . - - . - . - - - - - -                                         . _ . . - -   - .         _ -              -

_6 A 10.0 GLOSSARY OF ACRONYMS AND ABBREVIATIQMS AEHA - U.S. Army Environmental Hygiene Agency AMC U.S. Army Materiel Command AMMRC U.S. Army Materials and Mechanics Research Center AMCCOM U.S. Army Armament, Munitions and Chemical Command ANS/ANS American Nuclear Socloty/American National Standard AR Army Regulation BRAC Base Realignment and Closure Act CAA Clean Air Act CF Cubic feet CFR Code of Federal Regulations CM Cubic Meters CMR Code of Massachusetts Regulations CTDOT Connecticut Department of Transportation ( .; DAOC' DMslon of A'r Quality Control

DHW- DMslon of Hazardous Waste-dis DMs'on of Industrial Safety DU- Department of Labor and Industries -

                  -DoD Department of Defense DOE:               Department of Energy DOH              - DMsion of Occupational Hygiene DOT-               Department of Transportation DPH                Department of Public Health dpm              : disintegrations per minute DSW                DMslon of Solid Waste 10 1                                  10/03/91 1

Printed on Recycled Paper

                                                              ._,...~ ,_ -- . _ _ - . _ . _ _ . . . , - . _ . _ . , , - - . , - - .             ,     , , . .   ,,..,_,--,_v,_   ,

                                                                                                                      .e ,i 10.0 GLOSSAFiY OF ACRONYMS AND ABBREVIATIONS (Continued)

DU Depleted Uranium EA - Environmental Assessment EIS Environmental Impact Statement FIRM Flood Insurance Race Map HABS/HAES Historic American Building Survey / Historic American Engineering Survey HEPA High Efficioney Particulate Adsorption IAEA International Atomic Energy Agency lABCOM U.S. Army Laboratory Commard LLW Low Level Radioacth/e Waste LSA Low Specific ActMty MADEP Massachusetts Department of Environmental Protection MDC Metropolitan District Commission MEPA Massachusetts Environmerital Policy Act MHC Massachusetts Historical Commission MOA Memorandum of Agreement MTL Army Materials Technology Laboratory MWRA Massachusetts Water Resources Authority NEPA National Environmental Pok:y Act NPDES National Pollution Discharge Eliminatbn System NRC Nuclear Regulatory Commission NPHP National Register of Historicsi Places OSC Open Space / Conservation Zoning OSHA Occupational Safety ar.d Health Administration pCi pico curies 10-2 10/03/91 Fmntec on Recycled Pacer

i, t. 10.0 GLOSSARY OF ACRONYMS AND ABBREVIATIONS (Continued} PGB Program Budget Guidance REC Record of Environmental Considerations SCS Sol: Conservation Servico SF Square feet SHPO State Historic Preservation Officer SNM Special Nuclear Material

     -TSD   Treatenent Storage and Disposal TSP   Total Suspended Particulates TRC   TRC Environmental Consultants, Inc.

uCl micro curies USEPA United States Environmental Protection Agency USGS United States Geological Survey 10-3 10/03/91 FwE Recycled Riper

i, 4 11.0 LIST OF PREPARERS Tracy W. Stenner, Senior Environmental Scientist, ABB Environmental Services, Inc. David E. Holstein. Environmental Engineer, ABB Environmental Services, Inc. Daniel J Sheehy, Depa1 ment Manager Applied Ecology, ABB Environmental Services, Inc. Philip Rosenthai, Program Manager. NoHear Fuel Manufacturing, ABB Combustion Engineering Nuclear Power l l l l 11-1 10/03/9t l. l r-,w nu,ee e.- l l l

                                                      ..                         . - , .  . ~ - , ,        _

   ,,- ,,,-                                                            ;e APPENDIX A RADIATION SURVEY RESULTS, ESTIMATED VOLUMES OF WASTE AND ACCEPTABLE SURFACE CONTAMINATION LEVELS o

FOR TOTAL AND PARTIAL DISMANTLEMENT i . . . .

 ., g:

TABLE A 1

SUMMARY

OF THE RESULTS OF THE MTL BUILDING 100 SMEAR SAMPLING Bota Gamma Alpha

                 ,,qcat]gn,                          fdom/100 cnf)        _ldom/100 cnf)

_ElasemenL Inside Tubes of the Storage Facility 293 <20 All Other Basernent Smears <200 <20 _ Main Floor-- All Main. Floor Smecra < 200 <20 JjIst P;atform All First-Platform Smears < 200 <20 L _.SEC.pnd Plat (otaL All Second platform Smears < 200 <20 Reactor Vossg! Internals Floor by the Access Ladder 204 <20 All Other Reactor Vessel Internal Smears < 200 <20 Reactor Annufts

       ' Stainless Steel hael<s                         293 395                   < 20 Annulus Floor                                  200 725                   < 20 Stainless-Steel Piping below Reactor Grte                                  749 - 5707                 <20 Ref: EG&G,1990s dpm = disintigrations of radioactive nuclides per minute cm a centimeter

                                                                                                                                                           / ,i TABLE A 2

SUMMARY

OF THE RESULTS OF THE MTL BUILDING 100 RADIATION SURVEY Location Contact.Asdlation Readina (mR/h) _ asement Demineralizer . . ...... ... ... . . . .,.. . , .... . .. 2.0 6.0 Heat Exchangers . . . . .. .. . . . .. .... ... . .. . . .. .. ..... 0.3 Fission. Product Monitor .... .. ... .

                                                                              . ........ .... ..... . ...                                          . 0.05 Main Floor Calitomium-252 Source . . . . . . .                 ... .          . . ...... .. .                 ... .....                        ..        . 16.0 Mobile N. Ray . .     ...... ... ..                      .    .. ... ..... ....                  . ... ... .. .....                                  0.2 First Platform Reactor Kesper Slide . . . . .           . . .           .... . . .. . .....                  . . .. .                     .,         .. .         . 02 Second Platform Reactor Top . .     .... .. .. . ... ....                          .... ..... . . . .....                                       .....         .. 0.7 Magnets in Cabinet . . . . . . .        .,         .. .,         ... ...... .............                                 .... ...               . 0.4 Reactor Vessel lntemals__.

Blind Flanges . . . . . . . . . . . . ... .. ..... ....... ... . ... ... .. 50.0 - 550.0 Stant Tubes . .... .......... ... .. ......... ......., .... ..... 8.0 30.0 Valves . . . . . ........................... ... .... . . . . . . . . . . . . . . . . 10.0 60.0 Ped estal (top) . . . . . . . . . . . . . . . . . . . . . . . . . ..... .............. ..... ..... 550.0 Pedestal (bottom) . . . . . . . . . . ....... ...... ... .. . ....... ............ 15.0 Reactor Annufus Stainless. Steel Racks and Stainless. Steel Pipe . . . . . . . . .. ... .. . ... . . . 55.0 Below Reactor Gate . . . . ... ........ ............. ..... . . . . . . . . 1,300.0 General Body Field by Stainless-Steel Pipe at 3 ft - . . . . . ... .... , ... ...... 18.0 Ref: EG&G.1990a mR/h = milli-Roentgens i

f TA3LE A-3 VOLUMES OF WASTE TO BE GENERATED BY PARTIAL AND TOTAL DISMANTLEMENT Contaminaied Waste Stainless Steef Other Metaf Concrete' Othe/ Total Attemative 3toel' (#n (f?) (ff) (f?) (??) ttfi

1. Partial Dismantiement 130 200 150 6.750 0 7.230

2. Tota! Dismani;ement 130 200 150 6,750 0 7.230 Uncontaminated Waste Stalrdess Steel Steel Other Metaf Concrete Othe/ Total A!!emative (f?) (ff) (fd) (if) (ff) (*f )

1. Partiai 0 1,500 0 6.800 6.000 14.300 3

Dismantiement

2. Total Dismantiement 0 3,000 0 78.000 15.000 9G 000i'

a. Principal radionuclide Co40, activity 23 Cl. Bea+mitting radionuclides produced by neutron activation are not inciuded, but wal be identified during decommisskning.

b. Principal radionuclide Mc-54, activity 0.15 milli Ci. Beta +mitting radionucides produced oy neutron activation are not included, but wi:I be identified during decommissioning.

c. "Other Metal" category includes components from inside the reactor vessel According to information from EG&G personnel famHiar with hazardous-waste regulations, berynium oxide is not currently RCRA regulated and therefore would not be mixed waste.

d. Principal radionuclides Cs-137, Sr-90 ar>J Co40, acth,1ty unknown Beta-emitting radiocuclides produced by neutron activation are not included, but wBl be identified during decommissbning.

n

                            ._y   .

TABLE A-3 VOLUMES OF WASTE TO BE GENERATED BY PARTIAL AND TOTAL DISMANTLEMENT (cont.)

e. "Other" category indudes galvanized sheet metal, mctor control panels, control room equipment, metal piping, and substation transformers.

f. Actual total quantity of waste to be disposed with a packaging void ratio of 10% to 60% is 7,425 ff to 11.138 ff.

g. An aveisge density of the total material was estimated by EG&G resulting in a total weight of approximately 470 Tons.

h. An average density was estimated by EG3G resulting in a tota! weight of approximately 5,000 Tons.

flei: EG&G,1990b.1991a l I r l l l e.

l .. s. l I l l TABLE A-4  ! l ACCEPTABLE SURFACE CONTAMINATION LEVELS NUCLlDE' AVERAGE" MAXIMUf#' REMOVABLW U nat, U 235, U-238, and 5,0p0 dpm a /100 15 000 dpm a /100 1,000 dpm a /100 associated decay products crrr ent enf Transuranics Ra 226, Ra-228, 100 dpm/100 crd 300 dpm/100 crd 20 dpm/100 cnf Th-230, Th-228, Pa 231, Ac 227,1125.1129 Th-nat, Th-232, Sr-90, Ra 223, 1,000 dpm/100 crd 3,000 dpm/100 crd 200 dpm/100 crd Ra 224 U 232,1-126,1131, 1133 Beta-gamma emitters 5,000 dpm a-y/100 15.000 dpm a n /100 1,000 dpm an /100 (nuclides with decay modes enf cnf cnf other than aloha emission or spontaneous fission) except Sr-90 and others noted j above.

a. Where surface contamination by both alpha- and beta-gamma ernitting nuclides exists, the limits established for alpha and beta gamma emitting nuclides should apply independently,

b. As used in this table, dpm (disintegrations er minute) means that the rate of emission by radioactive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.

c. Measurements of average contaminant should not be averaged over more than 1 square meter.

For objects of less surface area, the average should be derived for each such ob

d. The maximum contamination level applies to an area of not more than 100 cnf, ject.

e. The amount of removable radioactive material per 100 crd of surface area should be detemilned by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency. When removable contamination on fixed objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.

f. The average and maximum radiation levels associated with surface contamination resulting from beta-gamma emitters should not exceed 0.2 mrad /hr at I cm and 1.0 mrad /hr at 1 cm, respectively, measured through not more than 7 milligrams per square centimeter of total absorber.

Ref: NRC,1974,1987.

e, s. APPENDIX G ASE TOS ABATEMENT AND BUILDING DEMOLITION REQUIREMENTS

., s. APPENDIX B 1 FEDERAL (USEPA) AND STATE (DAOC) ASBESTOS ABATEMENT NOTIFICATION REQUIREMENTS AND FORMS I

e- 's, t i NOTIFICATION REQUIRIMENTS FOR ASBESTOS ABATINENT_

y. EPA (Environmental Protection Agency)

            ,k           NESEAP5. Requiroment - whenever asbestos is being removed
      .              A.                                                                                  .

1. Demolition - 10 days notice if greater tban 260 linear feet or i

160 square feet 1-

                                                  - 20 days notice if less than 260 linear feet or 160 square feet

2. Renovation - As soon as possible before work begins if greater i

than 260 linear feet or 160 square feet i i - No notification requirement if less than 260 linear l

         '                                           feet or 160 square feet 3

Information Required cn NESEAPS notification (Suggested form on page 11-4.

                                        - Name and address of owner or operator
                                        - Size, age, prior use, location of facility
            )
                                        - Amount of friable material in facility
                                        - Scheduled start and coupletion dates 'f pr, ject
                                        - Procedures used to comply with NESHAPS S'tidard (i.e. - vet methods)
                                         - Waste disposal site to be used.

B. TSCA Requirement - Whenever public enployees are doing any type of asbestos abatement project involving more than 3 square or 3 Linear feet of asbestos including removal, encapsulation or enclosure.

1. If a NESEAPS notification is filed, it is not necessary to notify under TSCA - provided that the NESEAPS notico includes the fact that public employees will be doing abatement work.

11-1 b

2. Inftraatirn R: quired en TSCA estifiontica

                             - Postmarked 10 days before project begins 4

j

                             - Employers name and address                                                                     [

t'

                             - Location, street address of facility where abatement project 15 scheduled
                             - Start and completion dates II. PE9E E     (Department of Environmental Quality Engineering)

1. Information Required for all asbestos removal projects. Contact ,

                . Regional DEQE Office. See Section 23 for addresses and telephone nunbers.

4 1

                       - Notify 20 days prior to asbestos removal l                       - Name, uldress, location of facility
                       - How much asbestos is to be removed I                        - Start and completion dates
                        - Vbo is removing the asbestos F
                        - Work practices used to minimize hazards and to comply with NESEAPS
                        - Where the asbestos will be disposed.

III. DOH (Division of Occupational Hygiene) ,

1. Information Required

                        - Notify at least 10 days in advance for all asbestos abatement projects including removal, enclosure and encapsulation                               I
                        - Name, address, location of facility
                        - Contact person and telephone number
                         - Details of the abatement project (i.e. - removal vs.

encapsulation) j. s

                         - Who is performing the abatement project 11-2                                                             .

S l . , = . . . . - - . - . . . _ . . _ . _ _ , , , _ _ _ , , _ , , , , _

      ""N                 - - --  _ - - _ _ . .   .                     ,

y'

       -  How much asbestos material is being removed, enclosed or encapsulated
       -  Scheduled start, and completion date
       -  Work practices being used to decrease exposure including type of respirators to be worn by workers.

I 1 f 11-3 j

rocLITIL2VRmttl8.c w.. .m.a a . . , m. 1 (as required in Titic 40 crA Part C1, Wet M, 561.146 ". 'p f , ed tre ucsm e Aso-stos standanu .? I

                                                                    .

• i tune of cyerator/(>mer: I P A::kirers of operater/C>mer: l l

Phere: Age Dis::riptien of racility Size: _ Prior Use: ( f t . er sc. f t . ) l Anount of Triaole Asbestes Present: i ( f t. er sc. f t. ) l , et cf Friable Asbestos to t:e Fa.W. : I j ll Jck:ress of racility: i Cmpletirn Dste: Star .irq Date of Re::cval: 6 s 4

                                                                                                                                     \

Naturo of Dmolition/sterevaticn Pet.%$ Used: \

                                                                                                                    .                1 Proced'.:res Used for Cm.pliarce with Su.W M:

I 1 l I Nare/I.ocation of Waste Disp:: sal Site: Name/htle/Auttority of Ageref ori.rirq Drolition: _ (for projects described in 561.145(c)) _ _.m n, ' { li 4 11-4 ' i I

   -,3- .',

APPENDIX B-2 TOWN OF WATERTOWN, MASSACHUSETTS COURTESY NOTIFICATION PROCEDURES FOR DEMOLITION OF FACILITY (REQUIREMENTS AND FORMS) i i: I

I (.T' ..k TOWN OF WATERTOWN 111:l'A101 Ml;NT of CO%1h1UNilY 1)i. vel.Ol'A11:NT and I'lANNING

          ': i*.*        ,

• t-l'\Cil.I'lilN INNI'LC1lON Division k' Tdeninntration linilding 4*YN #  % A i 1:Ir19% N, 51 \NS ACill:Sl;1*l s 4:1*'2 nsnnon or uviunNcs xm t !>r t
• A

(*g # 4ak. PROCEDURES FOR RAZIllG/DEMULITIOli I 0F BUILDIf1GS THE FOLii' ,114G PROCEDURES ARE REQUIRED BEFORE OBTAI!1111G A BUILDI!!G PERh!T RA"E/DE110LISH A BUILDI!JG.

1. Obtain Building Permit Application

2. File Anbestos 21otification Form, Dept. of Labor e.

Industries if applicable. (Form Enclosed)

3. Contact Board of Hedith

a. Rodent Control Sign-Off with copy of Contract from a licenced Pest Control Company

b. Return Rodent Control Form To Health Departnent (Form Enclosed)

4. Utility Sign-off Sheet Must be Completed (Form Enclosed)

5. 110tification of work and Approval Sign-Off Sheet of the following Departments (Form Enclosed) i

a. Fire Department d. Wiro Inspector

b. Plumbing Inspector e. Health Department

c. Police Department-Traffic Division

                                                         -   -                                    -      ,r,    .

 -w - , - - . - . - . . . .                                      ~ . . . _ . . _ . - . . . - . . - - .                                              . - . _ . -                   -
                                                                                                                                                                                                .-_.~.--

h

                                                                                                                                                                                                                         .<'               s

[

                                                                                                                ~

2- , s

                              - Proceduros For Ra::ing/Domolition of Buildings i

6. The following is required for Public Works Sign Off:

a. Performanco Bond In The Amount of $5,000.00 made out to the Town of Watertown.

L

b. Domestic water service shall be disconnected-at main '

and corporation. shut off.

c. Fire se Leo shall have two foot section removed at property line.beyond gate at side walk.

Romaining pipe from gate shall be capped.

d. Sewer and drain service shall be disconnected at  ;

main and plugged.

e. Street opening permit required from Public Works prior to digging sidewalk or street -

f. All sidewalks and aprons shall be Icft in good repair and replaced-if damaged.

F 7.- Affidavit Form for Debd s  ? O t formrazo.mma , 5 z- te..*- s pe.w--y4. = ,.s >, ,,e - e. , ,,.a.9,eqvmWN*--54* 7"FM*FP hew" N-'WW't'WT'4W*Pf'*1P" ***-M4-Me**FTT"W"MT*7 4' 99**7 ' ' " *9*"MWPd 'Td"" TIM W "WYW-TTE'#M"

  '~             _.   . . . _ . - - - - - - - -                 - - -
                                                                                        . - -  - . .---- - - - - - -                ~       -

and PLANN1NG

                                                                                                                                               ~~l
     ~

f ' '.

       ',           '-  l                                  DUILDING DIVISION                                                        dt       -

APPLICATION FOR PERHIT ~ De rtui t n __ ; ( In accordance with Section 113.0,"Apniication For Permit" Hasanchusettu State Buillding Code, the undersigned hereby applies for a permit to: kgxxxxgtXRRKitMXXYMEXXXXXMYyr&Y.1HK DEMOLISH / RAZE  ; 1 Street & No. __ _ t Owmer_ Address . Te1# Architeat/ Engineer Address Te1# Builder._ Address Te1# License No. Expires Use and Occupancy of All Parts of Building _  ! If A Dwelling No. of Families Size of Lot: Front Rear _Left Side __ _,Right Side Size of. Building: front Pehr Left Side ' Right Side Distar.ces To Lot Line Of The Prposoed Structure / Building: 8 Front Rear _ Left Side Right Side GENERAL DESCRIPTION 0F PROPOSED WORK REQUIRED ON REVER Submitted: Plans _- Specifications _ ,,_P l o t Plan Duplicate-Sets of Plans Required ASSESSED VALUES Permit Fee t L Signature . L i Address __ TeI# Day l Approved-.By: Date . , f C. Nancy Scott Zoning; Enforcement Of ficer John P. DeToma

                                                                                                                                      ~

Inspector of Buildings r

w.yr- . . -

                        .                                                           ( .:r(Cu/[W                      b0                 dox               '                         .*

2eMdmod c;/.!adon and $nada.%:e.s OTTICT OT THE COXM!S3IONIF 'MM O Gh

• J W.E S T . S N 0**.'

                                                                               ,evere:t
                                                                                .                    Saltonstall Svilding. Covernment Center 100 Oa: bridge Street, Boston, MA 02202 N07 T!0A;;0N CT ASBESTOS '.' ORT.
       ~1n act:rf.ance vi:h the provisions of                                          M.O.'.. c. 4 I 9 .ss. 6-6T and 453 CS 6.12) 0-dav ??'0* NOT!T! AT 0 N 07 A:. .' A3 A T D'!"7 P ' .7.* I:T O E r 4 T E R Tvr1 3 '. :NEAR OR SOUARE Ftr; An se::1cns of                   .~.:.s      for: : ,. s : ce :::;.e::: :n er:er to co: ply with tne nctiti;ation requirs ents et 453 O n 6.12
        .=                . . . .               ..               .
     *acility Owner                                           .

inte , Telephone No. lusiness L:ca:1cn (5:ree:) i ty / To vn_,,, 5 ::. : e . ;1p

     ' ailing M.;te ss
     'ity/ Toe                                                         State                                                                        tip

ntity or herren verfe--ine er.d e:: '~ ~ " ~~~ "'" ' ' ' ~ "' ' *

     .usiness Lo:c:.on (Street)

Oity/Toyn 4: ate i 21p kiling Adv.ress

                                                                                                                                                  ;;p
                                                                                                                              ^
    ;1ty/Tcvn                                                       5:ste
 ~ 'assachuset:s A.sbestos Contractor 1.1:ense No.
    .                                                                                                                                                                                      l l
    ,'P c quir e d .c.f t.e r. 5 /.2 / 6 6 ) . . .

lorkers Co:persation Insurer Policy No. So preva111cs ra:es of vage apply to this preji:t as required under M.G.L.

.149, es. 26, 2 7 or . 2 7Ft Tes No

1s asbestos contract vritten verbal 1

   .A.ddress of protect                     - "    - - - - " ' ' -

Street ! Oity/L a_ 5:a:e Zip l l rresent use of f ac111Ly Intended use (if knovn) l Descrierion et fac!!it.y -- .

Type of Building Si

e Age of facility Nature of the ;rof eet.

Dec.clitten ~ Renovation Other (Specify)

Nature of the Asb=stos Activity Retoval Enclosure.  ; Encapsulation . t Indicate amount in linear feet of asbestos surface on pipes or ducts or square feet of asbestos surface on structures otner.chan pipes or ducts to be re:eved, enclosed or encapsulated Start date ccepletion date_ A.M.; __ .P.M. Veekends Ne e of Supervisor /Tereperson en preject Massachuset:s Supervisvr/Foreperson Cer:1ficati n # (required af ter 5/2/83) Descriptien of work practices to be followed (to comply with 453 rMR 6.144 Descriptior of decontamina:1:n syste:(s) to be sued (:o ec= ply with 450 CMR 6.14 (2) (b) Description of handling / disposal :eth ds to cc: ply vi:h 453 CXR 6.14 (2) (g) Na e, adcress/ Location of disposal si:e(s)

 "4:n, address of transpor:er (s) if other :bpn asbestos contrac:or
    ..as of Asbistos Abate:ent Project monitor (if applicable) forson/ firm Address                                                                                                                                 __

The undersigned hereby states, under the penal:1es of perjury, that he/she has read l and' understood the Co enveairk of Passacnuse::s Kegulations for the Recoval, con-tain=ent, or Encapsulation of Asbestos, 453 CMR 5.00, and that the information contained in this actification is : rue and correc: :o :ne best of his/hcr knowledge and belist. l Date Signed by: l Ti:le l Of 1 l Return to: AS3ESTOS CONTRCL T!;HS! CAL SERV!CIS DEPARTMENT OF LA30R A C !N0'J37R:25 - l 100 Cambridge 5:ree:

Boston. Massachuset

s 02:02 5

k .* .i

                                )

TOWN OF WATERTOWN Massachusetts BOARD OF HEAL.TH Marvin t. Mdchell. M O. Karen L Noumjian, O D. JDsEPH J Divi 00 Jettph t. C Santoro 0< rector of podhe s ea.ah RECO:*iE!DED GUIDELINES PCR RODCIT CONTROI. '

                                                                                                                 - - - - - ~ - - - -

1. - - - - - -

Prior to excavation or demalition of a bJilding, the owner shall comply with the followings a. Hire a qualified Ev erminater to survey the area and take necessary actica -(bait 2ng etc.) b. Provide Building and Health Departments a detailed report. The report should in:lude prc;0edures and redenticides used and measures being taken to prevent future rodent infestation

c. ,

The Ex.tcrminator should continue to monitore the demo for at least 30 days after the permit has been issued and take whatever action necessary to control the rodent infestation. I_ owner of hereby swear under penalty of perjury the above steps a en and will be t k also affirm the building is free of any asbestos. l [ i6 ministration Dullding . Watortown. Massachusottn 02172 '

1. . n . o o , ** "" '

i l , _

  ,. ,.   ,x;Qt.

[y ' . .' TOWN OF WATERTOWN f

                        .u      til:l' Alt 151EN'l of CON 1\10NflY DITl:1.Ol'%11.NT und I'l.\NNIMi En          pa '                    l'AClI,11II;S INN 1'lEllON IH\'IstoN 4       [M#                                     Adtninhtrution llui ding f                     WYI 1:ll'l OWN, Al %% %Citt'NI:l*l s 0217:

twt cron oi tauncs r ,,m r ev s UTILITY SIGN-OFF SHEET In accordance with Section 116.1, Maccachusetts State Buildina Code, " SERVICE CONNECTIONS" with regard to Demc'ition of ' Huildings, please note:

                  "Before a building can be demolished or removed, the owner or agent shall notify all utilities having s,orvice connections within the building such as water, electric, gas, sewer and other connections (telephone).             A permit to domolish or remove a build-ing shall not be issued until a relense is obtained from the utilities, statin.) that their respective service connections and appurtenant equipment cuch as meters and regulators have been removed or sealed and plugged in a safe manner."

THIS FORM MUST BE COMPLETED AND SUBMITTED TO THE BUILDING DEPARTMENT ACCOMPANYING YOUR APPLICATION FOR A BUILDING PERMIT. A PERMIT WILL NOT BE ISSUED IF THIS FORM IS NOT COMPLETED. LOCATION I certify that as a representative of my company, said utility has been disconnected. Electric Company Title 'Date Gas Company Title Date Telephone Company Title Date Public Works & Sewer Superintendent,DPW Date utilsign,ma l l____--_--__-____-_-----_------------------------------ --

bg ($R, TOWN OlbWATNRTOWN ,,

                    . .S.. DI:l'A R i h11:N'l of Coht%1tlNiiY DITI.l.Ol'hti:NT and I'lANNING 1W             M' h'n-                  l'ACl!.I'lli:s INNI'l:CTION DIVISION

[lde, f. Adminkerution llullding

                        /               W.Vil:lflOWN, $1 \NSACill:Sl:Tl'S 9217 INq1 cum or m'UDtw ru e ta mus 9'J I, ni' DEPARTHENT NOTIFICATION FIGN-OFF It is the intent of (Contractor / Owner) to demolish the building located at Said work to commence on_

I have been notified of cuch work and my signature below indicates my approval. Fire Department Title Date Inspector Plumbing / Gas Date Police-Tratf1E Department iitic Date Inspector of Wires Date Board of health Title Date depnotif.ma l l l

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(g. .,,,a .. f., I)l:l'ARTA11:N r of Cm15tt'N11Y DINEl.di'StCNT and I'lANMNG *

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                                  ' '(2y i- L FACll.!~111.S INS 'EC'llON 1)lVISION
                                      ,                                Adminhtration llullding WATl'.itTOWN, A1ASSACllUS!!!TS 0:172 1NSPECTUR OF DUILDINGS acun> ctm uA mue AF 1D AVIT As a result of the provisions of MOL e C,554, I acknowledge that as a e. n ition of Building Permit Number                                          all debris resulting from the construction activity governed by this Building Permit shall be disposed of in a properly Icensed solid waste disposal facility,'as defined by MGL c til, S 150A.

I certify that I will notify the Building Offi:ial ty _ (Two months maximum) of the location of the solid waste disposal f.tcility where the debris resulting from the said construction "ctivity shall te disposed of, and ! sha!! submit the appropriate form for atta:hment to the Building Permit.

                                                      ~

Date Signature o' Permit Applicant (Print or type the following information) Name of Permit Applicant Firm Name, if any Address

1 Uit.N Vf i).llt,h l V O d

                                        ~

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y, s. 1)l-:l'AltTA11:NT of CO\151UN11Y DfNEl.Ol'N1ENT and l'1ANNING '

s FACil.ll:1.s INSl'ECTION 1)lVIS10N s

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Admini.trution llullding ' WATI:ltTOWN, A1ASSACllVSETTS 02172 INSPtcrDR OF Dti!LDINGS , scum p. etrou4 m4* In accordance with the provisient of MOL e 40, S $4, a condition of Buildin; Permit Number __ a that the debris ruulting frcm this work shall be

• disposed 150A.

of an a properly li;cnsed sohd waste disposal facilary as denned by MOL c 111, S

                                                  ~

The debris will t>e disposed of int (Lo:atier, of Facihty) Signature of Permit Applicant Date l 9 1

s APPENDIX C MASSACHUSE6TS HISTORICAL COMMISSION RESPONSE TO DECOMMISSIONING OF THE MTL REACTOR FACILITY l-I i-l I L s P b 1 l l k

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                                           ,          O        ~-               a       s K.        04.\tiss$' f October 3,1990                             %%sh          1      Ith t Melvin E. Mams Major AR Dcputy Director and Commander Department of the Arny U.S. Army Laboratory Command Materie.ls Technology Laboratory Watertown, MA     02172 0001 ATTN:   Laura Rodman RE:   Lester "uclear Research Reactor, Army Materials Technology Labcratory, Watertown Arsenal, Watertown, MA

Dear M4i or Adams:

Staff of the Massachusetts Historical Commission have reviewed the inforN. tion you submf tied, received September 4,1990, regarding the proposed diamantling of the containment facility for the nuclear reactor referenced above. The Lester Nuclear Research Reactor is eligible under Criteria O for listing in the National Register of Historic Places as a contributing element in the Watertown Arsenal Historic District. MHC staff understand that the existing reactor represents a substantial hazard to public health and safety. In addition, MHC staff understand that the Department of Defense is under a time constraint to complete removal of the reactor before tne State's 1992 moratorium r.n the removal of hazardous waste. Given the important public benefit to be gtined from the removal of the reactor and given that the reactor is chitfly eligible for listing on the National Register under Criteria 0, the croposed removal of the reactor will have no adverse ef fect (36 CFR 800,9(c)'l)) provideo the followin5 condition is met: the Lester Nuclear Resear:h R'.rsctor is recorded according to HABS/HAER documentation standards; copies of the documentation w111 be submittert to the National Park Service for transmittal to the Library of Congress and to the MHC for transmittal to thi Massachusetts State Archives. Either partial or total dismantling of tne reaeor would be acceptable. A copy of these comments should be submitted to the Advisory Council on Historic Preservation together with your project documentation (36 CFR 800.8). Shuachusett> Histoncal Commmion.Llene A. Talmage, fremt:tr Directer, Statt Huroerr Prorrvatten Opm 80 Bovtston Street, Boston Sianachusetts 02116 (617)727 8470 Office <>f the Secretary of State. .Whaelj. Connolly. Suretary _ _ _ ___ _ ~

v .. i L These comments are prov?ded to assist in compliance with Section 106 of the National Historic Preservation Act of 1966, as amended (36 CFR 800), if you have any questions, please contact Allen Johnson of this office, Sincerely, (J wWA wm Brona Simon Deputy State Historic Preservation Officer Massachusetts Historical Conimission ec: Marie Bourassa, New England Corps of Engineers Watertown Historical Connission ' Advisory Council on Historic Preservation

    #,    'b APPENDIX D U.S. ARMY IMPLEMENTATION OF REVISED 10 CFR 20 l

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 ,.      s osPAnTwaNTGF THE ARMY                                     /        '\

cFrica of TH: ass 48 TANT Sf,CARARY wwmow, w aanan [

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upg;L, 11 JW 1981 *g j 1 l Dr. John L. Glenn Chief, Medical 3.nd Commercial Usa Safety Branch U. S. Nuclear Regulatory Ceraisaton Mdil $Dop 6H3 Ono White Flint Washington, D. C. 20555

Dear Dr. Glenn:

The May 21, 1991, Yoderal Register publishna the final rule for tha Huclear Regulatory Comminaion stand-azds for protection against radiation. The Department of Army licensees Will implement the new standard effec-tive January 1, 1993. The Anny has chosen the January 1, 1993, implement 4-tion date to allcw the Nuclear Regulatory Ccamission t;o publish guides to assist in the implementation of the new standard and to allow Army to instituto policy changes - required for implementation consistent with those guidess. If you have any additional quantions, please centset Hr. John Rankin or Ms. Patricia Elker with the U.S. Army Mater 161 Command at (703) 274-9475. Sincerely, l I.awis D. Walker Deputy Assistant Jacratary of the Army , (Environmerit , Safety and Occupation 61 Health) ' CASA (I,L&E) L l

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ct: O.S. Nuclear Regulatory Con. mission, Region I, , ATTH: Materials Licensing 3 ranch, 475 Allendale . Rd, King of Prussia, PA 19406 i U.5. Nuclear Regulatory Conusission, Region II, i i ATTNs Materials Licensing tranch, 101 Marietta St., ' ' NW, Atlanta, CA 30323 U.S.- Nuclear Regulatory Commission, Region ITT, ' ATTH: Materiale Licensing tranch, 799 Roosevelt Road, cien Ellyn, IL 601.'.7 U.S.11uolear Regulatory Commission,- Region IV, ,

                                                                .ATTH: Materials Licensing Branch, 611 Ryan Plaza                                                                                                                       ...!          .

Drive, suite 1000, Arlington, TX 76011 - U.5, .Huclear Regulatory Csauaias. ton, Region V, l ATTN Materials Licensing-aranch, 1450 Maria Lane,

• suita 210. Walnut Creek, CA 94396 . ,

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