Idaho National Laboratory (INL) Reactor Technology Complex (RTC) buried piping and components are being characterized to determine if they should be managed as hazardous waste and subject to the Hazardous Waste Management Act/Resource Conservation and Recovery Act (RCRA). RTC buried piping and components involve both active piping and components from currently operating nuclear facilities, such as the Advanced Test Reactor (ATR), and inactive lines from facilities undergoing D&D activities. The issue exists as to the proper methods to analyze and control hazards associated with D&D activities on facilities collocated with existing operating nuclear facilities, or future collocated facilities being considered with the resurgent nuclear industry. During initial characterization activities, it was determined that residual radioactive material in several inactive RTC lines and components could potentially exceed hazard category (HC) 3 thresholds. In addition, concerns were raised as to how to properly isolate active nuclear facility piping and components from those inactive lines undergoing RCRA actions, and whether the operating facility safety basis could be impacted. Work was stopped, and a potential inadequacy in the safety analysis (PISA) was declared, even though no clear safety basis existed for the inactive, abandoned lines and equipment. An unreviewed safety question (USQ) and an occurrence report resulted. A HC 3 or greater Nuclear Facility/Activity for the buried piping and components was also declared in the occurrence report.
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