Authorized Limit Evaluation of Spent Granular Activated Carbon Used for Vapor-Phase Remediation at the Lawrence Livermore National Laboratory Livermore, California

This report provides a technical basis for establishing radiological release limits for granular activated carbon (GAC) containing very low quantities of tritium and radon daughter products generated during environmental remediation activities at Lawrence Livermore National Laboratory (LLNL). This evaluation was conducted according to the Authorized Limit procedures specified in United States Department of Energy (DOE) Order 5400.5, Radiation Protection of the Public and the Environment (DOE, 1993) and related DOE guidance documents. The GAC waste is currently being managed by LLNL as a Resource Conservation and Recovery Act (RCRA) mixed waste. Significant cost savings can be achieved by developing an Authorized Limit under DOE Order 5400.5 since it would allow the waste to be safely disposed as a hazardous waste at a permitted off-site RCRA treatment and disposal facility. LLNL generates GAC waste during vapor-phase soil remediation in the Trailer 5475 area. While trichloroethylene and other volatile organic compounds (VOCs) are the primary targets of the remedial action, a limited amount of tritium and radon daughter products are contained in the GAC at the time of disposal. As defined in DOE Order 5400.5, an Authorized Limit is a level of residual radioactive material that will result in an annual public dose of 100 milliroentgen-equivalent man per year (mrem/year) or less. In 1995, DOE issued additional release requirements for material sent to a landfill that is not an authorized low-level radioactive waste disposal facility. Per guidance, the disposal site will be selected based on a risk/benefit assessment under the As-Low-As-Reasonably-Achievable (ALARA) process while ensuring that individual doses to the public are less than 25 mrem in a year, ground water is protected, the release would not necessitate further remedial action for the disposal site, and the release is coordinated with all appropriate authorities. The 1995 release requirements also state that Authorized Limits may be approved by DOE field office managers without DOE headquarters (EH-1) approval if a reasonably conservative dose assessment demonstrates that: (1) Public doses will not exceed one mrem per year individually or 10 person-rem/year collectively; (2) Appropriate record keeping and data collection procedures are in place; (3) Copies of the release evaluation and procedures are properly maintained; and (4) Coordination with all applicable state and federal agencies is documented. Based on the above guidelines, this report uses one mrem/year for individual members of the public and 10 person-rem/year for the collective population as upper-bound doses for the determination of Authorized Limits