ML16130A011
| ML16130A011 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 01/27/2016 |
| From: | Maloney M US Dept of Energy (DOE) |
| To: | Amy Snyder Division of Decommissioning, Uranium Recovery and Waste Programs |
| Amy Snyder 301-415-6822 | |
| References | |
| Download: ML16130A011 (29) | |
Text
From:
Maloney, Moira To:
Snyder, Amy
Subject:
[External_Sender] RE: Request Date:
Wednesday, January 27, 2016 4:22:51 PM Attachments:
367067.pdf Hi Amy, Hope that you are staying warm! Attached is our request to EPA for approval to use alternative methodology for radionuclide source term calculations for demolition activities at the WVDP. If I havent answered your request, please dont hesitate to call me.
- Thanks, Moira From: Snyder, Amy [1]
Sent: Tuesday, January 26, 2016 8:51 AM To: Maloney, Moira
Subject:
Request
HI Moira,
Working at home today-snowed in.
I think we got more snow than you this time.
Request that DOE send NRC the information (safety report/calculations) related to the alternative methodology for radionuclide source-term calculations for air emissions from demolition activities at the West Valley Demonstration Project.
If you have any questions, the quickest way to contact me is via my NRC email.
Thank you A
Amy M. Snyder, Senior Project Manager Materials Decommissioning Branch Division of Decommissioning, Uranium Recovery,and Waste Programs Office of Nuclear Material Safety and Safeguards 301 415-6822
Department of Energy West Valley Demonstration Project 10282 Rock Springs Road I. j West Valley, NY 14171-9799 January 25, 2016 Mr. Oleg Povetko, PhD United States Environmental Protection Agency, Region II Radiation and Indoor Air Branch 290 Broadway, 28th Floor New York, NY 10007-1866
SUBJECT:
Request for Approval for Alternative Methodology for Radionuclide Source Term Calculations for Air Emissions from Demolition Activities at the West Valley Demonstration Project
Dear Mr. Povetko:
Enclosed for your review and approval is an alternative source term calculation methodology for calculating the radiological emissions from demolition activities at the West Valley Demonstration Project (WVDP). The WVDP requests that approval be granted for the alternative source term calculation methodology presented in the enclosed. The approved alternative calculations will be used in lieu of Appendix D to determine maximum abated, potential, and realistic abated (if needed) emissions for the future planned demolition activities as allowed for by 4OCFR Part 61.96(b).
The WVDP believes that the proposed alternative calculation is more appropriate for the estimation of emissions of radionuclides from demolition activities, as demolition activities were not considered when the regulations were originally promulgated.
The WVDP is respectfully requesting approval of these alternative calculation methods 60 days from U.S. Environmental Protection Agencys receipt of this letter. If you have any questions regarding this request for approval, please contact Moira Maloney of my staff at (716) 942-4255.
Sincerely, ran C. Bower, Director West Valley Demonstration Project
Enclosure:
Methodology for Radionuclide Source Term Calculations for Air Emissions from Demolition Activities cc:
J. J. Hoch, CHBWV, WV-4PLEX, w/enc.
J. R. Fox, CHBWV, WV-4PLEX, w/enc.
T. W. Shearer, CHBWV, WV-PL6, w/enc.
C. A. Biedermann, CHBWV, AC-EA, w/enc.
J. D. Rendall, CHBWV, AC-EA, w/enc.
M. P. Krentz, DOE-WVDP, AC-DOE, w/enc.
M. N. Maloney, DOE-WVDP, AC-DOE, w/enc.
Paul Giardina, EPA, Region 2, w/enc.
B. M. Frank, NYSERDA, AC-NYS, w/enc.
MPK:367067 454.2.2
Rev 0 01/14/16 Methodology for Radionuclide Source Term Calculations for Air Emissions from Demolition Activities Prepared by:
Date:
01 / 14/16 B.C. Blunt Reviewed by:
Date:
JR. Fox WD:201 5:0598
Page 2 Table of Contents Demolition Activities.......................................................................................................... 4 Source Term Determination................................................................................................ 4 Purpose............................................................................................................................ 4 Background..................................................................................................................... 4 Methodology Description............................................................................................... 4 Demolition Methods...................................................................................................
5 Demolition with Mechanical Shears........................................................................... 7 Damage Ratio (DR)................................................................................................ 7 Airborne Release Fraction (ARF)........................................................................... 8 Respirable Fraction (RF)......................................................................................... 8 Leak Path Factor (LPF)........................................................................................... 8 Emission Estimation Equation................................................................................ 9 Demolition with a Hydraulic Hammer....................................................................... 9 Damage Ratio (DR)................................................................................................ 9 Airborne Release Fraction (ARF)........................................................................... 9 Respirable Fraction (RF)....................................................................................... 10 Leak Path Factor (LPF)......................................................................................... 10 Emission Estimation Equation.............................................................................. 10 Demolition with a Diamond Wire Saw..................................................................... 11 Damage Ratio (DR).............................................................................................. 11 Airborne Release Fraction (ARF)......................................................................... 11 Respirable Fraction (RF)....................................................................................... 11 Leak Path Factor (LPF)......................................................................................... 12 Emission Estimation Equation.............................................................................. 12 Demolition with a Wall Saw..................................................................................... 12 Damage Ratio (DR).............................................................................................. 12 Airborne Release Fraction (ARF)......................................................................... 13 Respirable Fraction (RF)....................................................................................... 13 Leak Path Factor (LPF)......................................................................................... 13 Emission Estimation Equation.............................................................................. 13 Equipment with Internal Loose Contamination (Segmenting).................................
14 Damage Ratio (DR).............................................................................................. 14 Airborne Release Fraction (ARF)......................................................................... 14 Respirable Fraction (RF)....................................................................................... 15 Leak Path Factor (LPF)......................................................................................... 15 Emission Estimation Equation.............................................................................. 16 Rubble Pile Emissions.............................................................................................. 16 Load Out Emissions.................................................................................................. 17 Miscellaneous Source Emissions.............................................................................. 1 8 Example Calculation..................................................................................................... 19 Summary....................................................................................................................... 26 References..................................................................................................................... 27 WD:2015:0598
Page 3 Glossary AED aerodynamic equivalent diameter ARF airborne release fraction CF Control Factor Ci Curie cm centimeter DOE Department of Energy DR Damage ratio EF Emission factor EPA Environmental Protection Agency ER Emission Reduction I
Inventory Kg kilogram lb pounds LPF Leak path factor m
meter m/s meters per second MAR Material-at-risk PS Physical State RF Respirable fraction ST Source Term UDCF Unit dose conversion factors WVDP West Valley Demonstration Project Micrometer WD:2015:0598
Page 4 Demolition Activities Source Term Determination Purpose This calculation estimates the emissions of radionuclides from the Demolition activities.
The calculation includes emissions due to physical demolition by various methods, moving debris to process piles, processing the piles and loading the rubble from the piles into sealed packages (containers).
Background
Demolition of facilities can involve several activities such as the demolition of the main building, moving debris and rubble from the demolition area to a processing area, sorting and processing of the debris and rubble, and loading the debris and rubble into containers for storage.
Each of these activities is analyzed in this document.
Methodology Description When demolition of the main building is undertaken, the physical demolition can involve equipment such as mechanical shears, saws, hydraulic hammers, and other means that are appropriate for the type of structure. This document analyzes those physical demolition activities that might be used at the West Valley Demonstration Project (WVDP).
Once the building or portions of the building are demolished, the debris or rubble is often moved to a processing area where the debris or rubble is size reduced and sorted. Finally the sorted debris or rubble is loaded into containers that are generally sealed.
Radionuclides contained in a sealed container of package are not included in the building inventory for purposes of estimating emissions.
In general, misting, watering, and fixatives are used throughout the demolition and load-out processes to minimize airborne contamination spread. Other methods that minimize emissions, and which are implemented on a case-by-case basis, are the use of windscreens or limiting demolition and load-out activities to times when the wind speed is below an acceptable limit. For example, at the Hanford Site, the air operating permit
[Hanford 2013] limits soil excavation activities to times when sustainable wind speed are less than 20 mph (8.8 mIs). At the WVDP, such limitations will be specified in work documents per industry practices.
Each step in the process will be evaluated separately in the following discussions.
WD:2015:0598
Page 5 Demolition Methods DOE facilities typically estimate airborne source terms using the following five-component linear equation [DOE 1994]:
ST MAR x DR x ARF x RF x LPF Equation I where: ST = Source Term
= the total quantity of respirable material released to the atmosphere during the demolition MAR = Material-at-risk
= the total quantity of radionuclide - in pounds (lb.) or curies (Ci) of activity for each radionuclide -
available to be acted on by a given physical stress DR = Damage ratio
= the fraction of the MAR actually impacted by the demolition conditions ARF = Airborne release fraction = the fraction of a radioactive material suspended in air as an aerosol and thus available for transport due to a physical stress from a specific activity RF = Respirable fraction
= the fraction of airborne radionuclides as particles that can be transported through air and inhaled into the human respiratory system and is commonly assumed to include particles 1 0-lim aerodynamic equivalent diameter (AED) and less. When RF = 1, all the particulate material is included in the calculation, and not just the respirable portion.
LPF = Leak path factor
= the fraction of the radionuclides in the aerosol transported through some confinement deposition system.
In AP-42, Compilation ofAir Pollutant Emission Factors [EPA 1995], airborne emissions or the source term is determined with Equation 2.
E=AxEFx (1-ER'
\\
/100) where: E = Estimated emissions
= the total quantity of material released to the atmosphere during the demolition A = Activity Rate
= the total quantity of radionuclides (in grams or curies of activity for each radionuclide) available to be acted on by a given physical stress EF = Emission factor
= relates the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant, in this case radionuclide.
ER = Emission Reduction
= the percent reduction of the pollutant due to some type of effluent control device or process.
Equation 2 WD:2015:0598
Page 6 Equation 2 is a form of Equation I where E=ST A=MAR EFDRxARFxRF (I-ER/I 00) = LPF A similar comparison can be made between Equation I and the emissions estimation method described in Appendix D to 40 CFR Part 61 [EPA 1989b], here after called the Appendix D method. The Appendix D method can be described mathematically as Equation 3 ED = I x PS x CF Equation 3 where: ED = Estimated emissions
= the total quantity of material released to the atmosphere during the demolition I = Inventory
= the total quantity of radionuclides (in grams or curies of activity for each radionuclide) available to be acted on by a given physical stress.
PS = Physical State Factor = relates the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant, in this case radionuclide.
CF = Control Factor
= the fraction of the radionuclides in the aerosol transported through some confinement deposition system.
Equation 3 is a form of Equation I where ED = ST 1= MAR PS = DR x ARF x RF CF = LPF The Appendix D method was developed by the US Environmental Protection Agency (EPA) based on emission estimates from various processes typical of that time [EPA 1989a]. However, none of these processes involved demolition activities. The primary factor that is often missing when performing the Appendix D method is a control factor for the effluent controls used at Department of Energy (DOE) facilities. This is the case for demolition processes, i.e. there are no control methods listed in Appendix D that are used in demolition operations. In addition, the demolition techniques used can have varying degrees of impaction on the facility, resulting in varying sizes of debris and rubble and varying degrees of aerosol creation. By using the more detailed Equation 1 the estimated emissions from the various demolition techniques can be refined and described WD:2015:0598
Page 7 mathematically. This calculation method is a mechanistic approach, much like AP-42, to calculation of radionuclide emissions from demolition activities.
Emission factors for several demolition techniques are derived in the following sections.
Demolition with Mechanical Shears Shears are two-bladed cutters acting as scissors. They are generally pneumatically or hydraulically operated. Mechanical shears are often used during demolition to perform "Cut; Shear; Break; Drop" operations. The "Cut; Shear; Break; Drop" approach can generally be described as cutting or shearing, breaking and dropping the building pieces to the ground within the controlled/regulated work area (drop zone). "Drop" would generally be "to lower carefully" based on strict procedural controls and conduct of operations.
Emissions using this demolition technique are estimated using an emission factor developed for similar activities by the Pacific Northwest National Laboratory (PNNL).
PNNL has been involved in estimating and verifying the emissions from demolition of several building at the Hanford site. One such demolition was the 224-U and 224-UA Buildings on the Hanford Site [Napier 2009]. PNNL used an emission factor of 5.OOE-05 lb. released per lb. of material demolished or in terms of radioactive contamination the units would be Ci released per Ci processed in the demolition. This emission factor accounts for the fugitive emissions resulting from demolition using mechanical shears when water misting is used as a control mechanism. After completion of the demolition, PNNL evaluated the emission estimates for this project against ambient monitoring conducted during the demolition and found that the calculated predicted emissions were similar to that measured on the ambient systems. Of note is the fact that most measured ambient emissions were at or below detection limits during demolition. [Napier 2010].
The following discussion describes how PNNL developed each term, with the exception of the MAR, in Equation 1.
Damage Ratio (DR)
When mechanical shears are used to demolish the buildings, it is assumed that the MAR is evenly distributed over the entire contaminated area being worked on (wall segment, floor area, etc.). The DR is that portion or percentage of the contaminated area acted on by the shear force. Jaws are assumed to fracture, crush, spall, or otherwise impact the surface being sheared. For a concrete block and reinforced concrete construction, the equipment is assumed to reduce essentially the entire portion of wall or floor being worked on to small pieces. For metal structures, including pipes and ventilation ducts, large portions of the metal remain intact and not converted to particle sizes that could be airborne easily. For this analysis, half of the surfaces are assumed to be rubblized and will remain too large to become airborne during demolition operations. Napier [Napier 2009] uses a DR of 0.5 for the demolition of the 224-U and 224-UA buildings at the Hanford site. As noted by Napier, this value is greater than that used for the Hanford Site 232-Z Building which was based on pulling down a block wall, and slightly smaller than that used for the analysis of the reinforced concrete walls of the Hanford Site 233-S Building.
WD:2015:0598
Page 8 Airborne Release Fraction (ARF.)
For demolition of walls and floors, DOE's factors for impaction stress due to vibration shock were selected as the most representative release fractions for the crushing processes; the factor selected was 0.001 for removable contaminants [DOE 199411.
EPA's [EPA 1995] compilation of airborne release fractions includes a range of uncontrolled release fractions for crushing of ores and rocks that range from 0.012 to 6 pounds per ton of ore, which relates to an ARF of 6E-06 to 3E-03 lbs. released per lb. of ores or rocks processed (in radiological terms, Ci released per Ci processed). As these ranges overlap, thus supporting the selection of the DOE values.
Respirable Fraction (RF)
The RF is the fraction of airborne radionuclides as particles that can be transported through air and inhaled into the human respiratory system and is commonly assumed to include particles 10-micrometer (lim) Aerodynamic Equivalent Diameter (AED) and less. For this analysis, more than the respirable fraction is involved. Therefore, as a conservative measure, the RF is set to I in all cases. This practice effectively assumes all particulate mater is released with no reduction based on size.
Leak Path Factor (LPF)
The LPF is the fraction of the radionuclides in the aerosol transported through some confinement deposition or filtration mechanism. For the purpose of this calculation method, the LPF is used to address any controls applied during and after the demolition process. This includes the effects of water mists, sprays, and fixatives applied to surfaces and rubble after demolition. The application of a water mist to contaminated surfaces during demolition serves to reduce the percentage of airborne particulates in the respirable size range. The efficiency of the mist varies with each application and depends on, among other variables, mist particle size, water flow rate, and the size of potential airborne particles. OSHA [OSHA 2009] cites several case studies where misting during grinding and while using vehicle-mounted rock drilling rigs resulted in a 90% decrease in dust generation. EPA [19952 and 2004] also lists watering as an effective dust control measure. Both references stated that up to a 90% reduction in emissions can be achieved by wetting of rubble piles.
For the purpose of this calculation, the water-mist application is assumed to reduce the quantity of airborne particulates by 90%, which results in a LPF of 0.1. The efficiency of the water-mist process must be weighed in light of the generated waste stream and the need to confine and capture runoff from the misting process. Thus, the LPF for concrete crushing is assumed to be 0.1. As noted by Napier [Napier 2009] this value is slightly lower than that used for the Hanford Site 233-S Building (0.3), based on observations of the effectiveness of the misting on that facility and during demolition of the Hanford Site 232-Z building. As previously discussed, the emissions when using this factor and the other factors discussed above for demolition with mechanical shears has been validated with ambient air sampling [Napier 2010].
Section 4.4.3.3.1 2 Section 13.2.4 Section 4.3 WD:20 15:0598
Page 9 Emission Estimation Equation By substituting the above factors into Equation 1 the emissions when using mechanical shears for "Cut; Shear; Break; Drop" demolition operations are found. The final equation is presented below:
ST = MAR x DR x ARF x RF xLPF ST = MAR x 0.5 x 0.001 x 1 xO.1 ST = MAR x 5.OOE-05 Equation 4 Demolition with a Hydraulic Hammer A hydraulic hammer may be used to demolish structures constructed of non-reinforced or lightly reinforced concrete. The equipment generally consists of a hydraulically or pneumatically driven chisel or hammer.
The following discussion describes the development of each term, with the exception of the MAR, in Equation I for this demolition operation.
Damage Ratio (DR)
When a hydraulic hammer is used to demolish buildings, it is assumed that the MAR is evenly distributed over the entire contaminated area being worked on (wall segment, floor area, etc.). The DR is that portion or percentage of the contaminated area acted on by the hammer or chisel force. in the case of the hydraulic hammer, the momentum, resulting energy imparted on the structure, and impact and vibration forces act on the entire structure being worked. Therefore, the DR for this operation is set to 1.0.
Airborne Release Fraction (ARF The hydraulic hammer can be used on both vertical and horizontal surfaces. Emission factors for both operations are evaluated separately and then the most conservative factor is used. This approach allows the equipment operator the flexibility to operate as needed and still be bounded by the emissions calculations.
The DOE's factors for large falling object impact were selected for this operation on horizontal surfaces [DOE 1994]. The highest measured ARF was IE-03, while the "median" value for all experimental configurations is 4E-04. However, DOE states that the data may not be bounding and suggests as a conservative measure that a bounding value of IE-02 be used for the ARF.
When operating on a vertical surface the emissions from this action are due to impact Stress. DOE's factors for Impact Stress on surface contamination were selected for this operation [DOE J9945]* The bounding ARF is given as IE-03.
Section 4.4.3.3.2 Section 5.1 provides a summary of ARFs WD:2015:0598
Page 10 For this type of operation, the conservative approach is to use the bounding ARF for the scenario where the hydraulic hammer is acting on a horizontal surface. This ARF is IE-02.
Respirable Fraction (RE)
The RF is the fraction of airborne radionuclides as particles that can be transported through air and inhaled into the human respiratory system and is commonly assumed to include particles I 0-rim Aerodynamic Equivalent Diameter (AED) and less. For this analysis, more than the respirable fraction is involved. Therefore, as a conservative measure, the RF is set to I in all cases. This practice effectively assumes all particulate mater is released with no reduction based on size.
Leak Path Factor (LPF)
The LPF is the fraction of the radionuclides in the aerosol transported through some confinement deposition or filtration mechanism. For the purpose of this calculation method, the LPF is used to address any controls applied during and after the demolition process. This includes the effects of water mists, sprays, and fixatives applied to surfaces and rubble after demolition. The application of a water mist to contaminated surfaces during demolition serves to reduce the percentage of airborne particulates in the respirable size range. The efficiency of the mist varies with each application and depends on, among other variables, mist particle size, water flow rate, and the size of potential airborne particles. OSHA [OSHA 2009] cites several case studies where misting during grinding and while using vehicle-mounted rock drilling rigs resulted in a 90% decrease in dust generation. EPA [19956 and 2004] also lists watering as an effective dust control measure. Both references stated that up to a 90% reduction in emissions can be achieved by wetting of rubble piles.
For the purpose of this calculation, the water-mist application is assumed to reduce the quantity of airborne particulates by 90%. The LPF is then 0.1.
Emission Estimation Equation By substituting the above factors into Equation I the emissions when using a hydraulic hammer for demolition operations are found. The final equation is presented below:
ST = MAR x DR x ARF x RF xLPF ST = MAR x tO x 0.01 x 1 xO.1 ST = MAR x 1.OE-03 Equation 5 6 Section 13.2.4 Section 4.3 WD:2015:0598
Page 11 Demolition with a Diamond Wire Saw A diamond wire saw typically involves the pulling of a multi-strand wire threaded with diamonds through the material to be cut. The diamond wire is threaded through a hole drilled at the top and bottom of the structure and guided through it via a series of pulleys.
The process itself eliminates vibrations, does not weaken surrounding structures, and produces very little dust or flying debris.
The following discussion describes the development of each term, with the exception of the MAR, in Equation I for this demolition operation.
Damage Ratio (DR)
The DR is that portion or percentage of the contaminated area acted on by the wire saw.
The wire saw removes a kerf of material the length of the cut. The material removed is then found as "width of ken" times the "length of cuts". Typically, a maximum of four cuts are required to produce a slab of material. The "length of cuts" would include all cuts needed to produce the slab. The damage ratio is then found by dividing the material removed by the area of the slab produced or DR - (Length of cuts) (width of kerf)
Area of slab For example:
Assume the kerf is 1.0 centimeter (cm) wide and the slab produced is 91.40cm by 91.40 cm (3 feet by 3 feet). Also assume 4 cuts are required, and all of the same length. Then the DR is 4(91.4 cm)(1 cm)
DR
= (91.4 cm) (91.4 cm)
= 0.044 Airborne Release Fraction (ARF)
The wire saw airborne release fraction results from the suspension of the contaminated material in an aqueous solution, which becomes a slurry. DOE's factors for free falling spill of slurries was selected for this operation [DOE 19948]. The bounding value of the ARF is 5E-05.
Respirable Fraction (RF)
The RF is the fraction of airborne radionuclides as particles that can be transported through air and inhaled into the human respiratory system and is commonly assumed to include particles I 0-tm Aerodynamic Equivalent Diameter (AED) and less. For this analysis, more than the respirable fraction is involved. Therefore, as a conservative measure, the RF is set to 1 in all cases. This practice effectively assumes all particulate matter is released with no reduction based on size.
Section 3.2.3.2 WD:2015:0598
Page 12 Leak Path Factor (LPF)
The LPF is the fraction of the radionuclides in the aerosol transported through some confinement deposition or filtration mechanism. There are generally no controls associated with this process. An LPF of 1.0 will be used for this calculation method.
Emission Estimation Equation By substituting the above factors into Equation 1, and then rearranging, the emissions when using a diamond wire saw for demolition operations are found. The final equation is presented below:
ST = MAR x DR x ARF x RE xLPF (Length of cuts) (width of kerf)
> 0.000 05>< 1 1
ST = MAR x Area of slab Equation 6 Demolition with a Wall Saw Wall and floor saws use circular diamond or carbide blades to cut a kerf in the material being cut. The blade is rotated by air or hydraulic motors. Floor saws, also called slab saws feature a blade that is mounted on a walk-behind machine. Walls saws, also called track saws, use a blade on a track-mounted machine. The dust produced by the cutting action is controlled using a water spray.
The following discussion describes the development of each term, with the exception of the MAR, in Equation 1 for this demolition operation.
Damage Ratio (DR)
The DR is that portion or percentage of the contaminated area acted on by the wall saw.
The wall saw removes a kerf of material the length of the cut. The material removed is then found as "width of kerf" times the "length of cuts". Typically, a maximum of four cuts are required to produce a slab of material. The "length of cuts" would include all cuts needed to produce the slab. The damage ratio is then found by dividing the material removed by the area of the slab produced or flR= (Length of cuts) (width of kerf)
Area of slab For example:
Assume the kerf is 1.0 centimeter (cm) wide and the slab produced is 91.40 cm by 91.40 cm (3 feet by 3 feet). Also assume 4 cuts are required, and all of the same length. Then the DR is ST =
MF-0 x MAR x (Length of cuts) (width of kerf)
Area of slab WD:2015:0598
Page 13 4(91.4 cm)(1 cm)
DR
= (91.4 cm)(91.4 cm)
= 0.044 Airborne Release Fraction (ARF)
The wall saw airborne release fraction results from the suspension of both fixed and removable contaminate into air. DOE's factors for venting of pressurized gases over a solid were selected for this operation [DOE I 9949] The bounding value of the ARF is 5E-03.
Respirable Fraction (RE)
The RF is the fraction of airborne radionuclides as particles that can be transported through air and inhaled into the human respiratory system and is commonly assumed to include particles 1 0-tm Aerodynamic Equivalent Diameter (AED) and less. For this analysis, more than the respirable fraction is involved. Therefore, as a conservative measure, the RF is set to I in all cases. This practice effectively assumes all particulate matter is released with no reduction based on size.
Leak Path Factor (LPF)
Although the dust produced by the saw is controlled with a water spray, the degree of control is unknown. Therefore, as a conservative measure, the LPF will be set to 1.0 for the technique.
Emission Estimation Equation By substituting the above factors into Equation 1, and then rearranging, the emissions when using a wall saw for demolition operations are found. The final equation is presented below:
ST = MAR x DR x ARF x RF xLPF (Length of cuts) (width of kerf)
>< 1 < 1 ST = MAR x Area of slab Equation 7 Section 5.3.2.3 ST = S.0F-03 x MAR x (Length of cuts) (width of kerf)
Area of slab WD:20 15:0598
Page 14 Equipment with Internal Loose Contamination (Segmenting)
Facilities destined for demolition often contain large pieces of equipment that are too large to remove as a single item, and have loose internal contamination. This equipment is decontaminated and dc-inventoried to remove the majority of the internal contamination prior to demolition, however some contamination will be very difficult to remove and will remain after the decontamination process is complete.
The following discussion describes the development of each term, with the exception of the MAR, in Equation I for this demolition operation.
Damage Ratio (DR)
The demolition process for this type of equipment can fall into two categories, which are discussed below. A DR of 0.10 is selected for both cases.
The equipment is too large to handle with another process and requires that it be broken into smaller pieces, but not completely size reduced. Assuming that the equipment is decontaminated and dc-inventoried prior to beginning the demolition, the material that remains will be the most difficult to remove. It is assumed that the process of breaking the equipment into smaller pieces will impact 10% of the remaining internal contamination.
2.
A mechanical shear, or similar type equipment can be used to break up the equipment. This will result in tears and holes in the piece of equipment. Assuming that the equipment is decontaminated and dc-inventoried prior to beginning the demolition, the material that remains will be the most difficult to remove. It is assumed that the tears and holes will impact 10% of the remaining internal contamination.
Airborne Release Fraction (ARF)
Internal contamination released due to tears, holes or segmenting of the equipment will be released to the air and then fall to the work area. The DOE handbook [DOE 1994]
discusses several sets of experimental observations directly related to airborne releases from falling powders. Based on work done by Suffer et al., the DOE handbook'° selected a bounding ARF of 2E-03 for the spill of UO3 and Ti02 powders freely falling into moving air from a height of 3 meters.
Another method of estimating powder releases due to falling in moving air presented in the DOE handbook11 is that of Ballinger, which is presented below as Equation 8:
'° Section 3.4.3.1.2 Section 4.4.3.1.3 WD:2015:0598
Page 15 ARF = 0.1064(M°125)(H237)/p1°2 Equation 8 where: M = mass spilled, kilograms (kg)
H = height of spill, meter (m) p
= density of material, kg/m3 For a 1-kg release of U03 powder, of density 7.29 g/mL (7290 kg/m3), from a height of 3 meters, the estimated ARF using Equation 8 is I.65E-04. Similarly, for Pu02 with a density of 11.50 g/mL (11500 kglm3) dropped from a height of 3 meters, the estimated ARF is 1.04E-04.
Once the powders fall to the ground, the ongoing demolition activities will result in rubble falling onto it. The DOE Handbook'2 indicates an ARF of about 1E-03 for suspension caused by objects falling into powder. Some data suggest that the release fractions could be as high as I E-02, but as noted in the DOE handbook, when these ARF values are corrected for burial by fallen rubble, the ARF is bounded by I E-03. Based on these observations, an airborne release fraction of 0.001 is selected for these demolition operations.
Respirable Fraction (RF)
The RF is the fraction of airborne radionuclides as particles that can be transported through air and inhaled into the human respiratory system and is commonly assumed to include particles 1 0-jim Aerodynamic Equivalent Diameter (AED) and less. For this analysis, more than the respirable fraction is involved. Therefore, as a conservative measure, the RF is set to I in all cases. This practice effectively assumes all particulate mater is released with no reduction based on size.
Leak Path Factor (LPF)
The LPF is the fraction of the radionuclides in the aerosol transported through some confinement deposition or filtration mechanism. For the purpose of this calculation method, the LPF is used to address any controls applied during and after the demolition process. This includes the effects of water mists, sprays, and fixatives applied to surfaces and rubble after demolition. The application of a water mist to contaminated surfaces during demolition serves to reduce the percentage of airborne particulates in the respirable size range. The efficiency of the mist varies with each application and depends on, among other variables, mist particle size, water flow rate, and the size of potential airborne particles. OSHA [OSHA 2009] cites several case studies where misting during grinding and while using vehicle-mounted rock drilling rigs resulted in a 90% decrease in dust generation.
For the purpose of this calculation, the water-mist application is assumed to reduce the quantity of airborne particulates by 90% resulting in an LPF = 0.1.
12 Section 4.4.3.3.2 WD:2015:0598
Page 16 Emission Estimation Equation By substituting the above factors into Equation I the emissions from demolition (segmenting) of larger equipment with internal contamination operations are found. The final equation is presented below:
ST = MAR x DR x ARF x RF xLPF ST = MAR x 0.1 x 0.001 x 1 xO.1 ST = MAR x 1.00E-05 Equation 9 Rubble Pile Emissions Demolition of a buildin or structure will result in the formation of rubble and debris piles. EPA [EPA 2004] recommends the use of the aggregate handling and storage pile formulas for AP-42 [EPA I 995]14 to estimate emissions from operations on open waste piles. The AP-42 formula is reproduced below as Equation 10.
(U/.2)
EF = 0.0016 k (M/) 1.4 Where:
EF = Emission factor, mCi released per Ci in the pile'5 k
=
particle size multiplier, dimensionless U = Mean wind speed, m/s M = Material moisture content, percent The particle multiplier varies with the aerodynamic particle size range. AP-42 lists a value of 0.74 for particles < 30 im in size. For demolition, there can be particles with the potential to become airborne that are larger than 30.im. To account for this, a value of 1.0 will be used for k.
The piles will be wet, due to the misting, when they are produced. The piles will be maintained in a wet condition with water spray and misting. In addition, fixative may be applied to the rubble piles. A 1% increase in moisture content will assumed when fixative is applied.
Setting k = I in Equation 10 results in the following equation for estimating emissions from rubble piles.
13 Section 4.1.1 Section 13.2.4 The AP-42 units are kg released per Mg material processed. If the units for contaminated material is Ci/Mg, the units then become mCi released per Ci processed Equation 10 WD:2015:0598
Page 17 (U/
2)
EF = 0.0016 (M/2) 1.4 This emission factor can then be substituted into Equation 2 to determine the source term.
Since the spraying and wetting of the pile is accounted for in the EF equation the ER term is set to 0. Keeping in mind that A = MAR and E = ST, the resulting equation is E=A xEFxERI
\\
/ioo)
ST = MAR x 0.0016 (U/22)13 (M/)4 X (U/.2)
ST = MAR x 0.0016 (M/)14 Load Out Emissions Load-out activities include picking up rubble with a front-end loader, a thumb and bucket on the excavator or similar equipment and dumping of rubble and larger pieces into transfer containers.
The EPA [EPA 20041j6 suggests an emission factor of 0.029 kg released per Mg processed. Using a conversion factor of 1000 kg/Mg, the factor becomes 2.9E-05 Mg released per Mg processed.
For radionuclide operation, the average radionuclide content of the waste material (Ci/Mg) will convert the emission factor to a Curie based factor. This mathematical operation results in an emission factor 2.9E-05 Ci released per Ci processed.
This emission factor can then be substituted into Equation 2 to determine the source term.
As a conservative measure no credit is taken for emissions reduction or controls, therefore ER
- 0. Keeping in mind that A = MAR and E = ST, the resulting equation presented below is E=AxEFx (1_ER/100)
ST = MAR x 2.9E-05 Equation 12 16 Section 4.1.4 Equation 4-4 0// 100 Equation 11 WD:2015:0598
Page 18 Miscellaneous Source Emissions During the demolition, it is possible that other processes could be used. For those processes not addressed in this calculation method emission estimates will be handled by the U.S. EPA approved method presented in 4OCFR6I Appendix D [EPA 1989] or with a revision to this method, followed by EPA approval prior to using any newly proposed calculation methods. The Appendix D method has previously been presented as Equation 3, which is reproduced below.
ED = I x PS x CF where: E0 = Estimated emissions
= the total quantity of material released to the atmosphere during the demolition I = Inventory
= the total quantity of radionuclides (in grams or curies of activity for each radionuclide) available to be acted on by a given physical stress.
PS = Physical State Factor = relates the quantity of a pollutant released to the atmosphere with an activity associated with the release of that pollutant, in this case radionuclide.
CF = Control Factor
= the fraction of the radionuclides in the aerosol transported through some confinement deposition system.
Some cutting of metal may be required during demolition activities. At the end of chapter 12 of AP-42 [EPA 1995], EPA provides information on emissions from cutting operations. The document provided, "Emissions of Fumes, Nitrogen Oxides and Noise in Plasma Cutting of Stainless and Mild Steel", contains a table that provides emissions based on the material removed in the cut. For example, with dry cutting of a 35 mm thick steel plate, 1% of the material removed is vaporized and emitted. The remaining 99%
remains on the cutting table. The PS factor for dry cutting of 35 mm thick steel plate is 0.01 for the material removed. The highest emission rate is 7% of the material removed.
Therefore, as a bounding value, a PS factor of 0.07 will be used for cutting operations.
Metal fumes from welding operations are similar to cutting emissions. Chapter 12.19.2.2 of AP-42 discusses controls for welding fumes. Typical controls listed in this chapter include high efficiency filters, electrostatic precipitators, carbon filters and particulate scrubbers. Therefore, when control devices are used to capture cutting fumes, the Appendix D control factor should be applied.
Should contaminated haul roads be used for the demolition project, the methods described by EPA [199517 and 200418] for unpaved roads will be used to estimate emissions from such uses.
Section 13.2.2 18 Section 4.2 WD:201 5:0598
Page 19 Example Calculation The following example illustrates how the above methodology would be used to calculate the demolition activities. The input data are hypothetical and the results are not assumed to represent any activities currently in progress.
Based on characterization of a facility the following inventory has been established at the time that demolition will occur. Note that the inventory is presented based on the demolition means and methods that are planned for various portions of the hypothetical facility. As stated above, this is a hypothetical example and is only presented to demonstrate the use of the alternative methods presented for approval.
Table 1 Inventory or MAR' Segmenting Mechanical Diamond Hydraulic Facility Wall Saw Large Shearing Wire Saw Hammer Total Radionuclide Inventory Equipment Inventory Inventory Inventory Activity (Ci)
Inventory (Ci)
(Ci)
(Ci)
(Ci)
Am-241 2.35E-03 5.04E-04 1.68E-04 1.68E-04 1.68E-04 3,36E-03 Cm-243 3.13E-06 6.72E-07 2.24E-07 2.24E-07 2.24E-07 4.48E-06 Cm-244 7.89E-05 1.69E-05 5.63E-06 5.63E-06 5.63E-06 1.13E-04 Cs-137 4.20E-O1 8.99E-02 3.OOE-02 3.OOE-02 3.OOE-02 5.99E-O1 Ba-137m 4.20E-O1 8.99E-02 3.OOE-02 3.OOE-02 3.OOE-02 5.99E-O1 1-129 6.94E-11 1.49E-11 4.96E-12 4.96E-12 4.96E-12 9.91E-11 Np-237 2.50E-07 5.37E-08 1.79E-08 1.79E-08 1.79E-08 3.58E-07 Pu-238 6.96E-04 1.49E-04 4.97E-05 4.97E-05 4.97E-05 9.95E-04 Pu-239 3.86E-04 8.26E-05 2.75E-05 2.75E-05 2.75E-O5 5.S1E-04 Pu-240 2.94E-04 6.30E-05 2.1OE-05 2.1OE-05 2.1OE-05 4.20E-04 Pu-241 6.50E-03 1.39E-03 4.65E-04 4.65E-04 4.65E-04 9.29E-03 Sr-90 5.08E-02 1.09E-02 3.63E-03 3.63E-03 3.63E-03 7.25E-02 Y-90 5.08E-02 1.09E-02 3.63E-03 3.63E-03 3.63E-03 7.25E-02 Tc-99 1.50E-05 3.21E-06 1.07E-06 1.07E-06 1.07E-06 2.14E-05 U-232 1.68E-05 3.60E-06 1.20E-06 1.20E-06 1.20E-06 2.40E-05 U-233 6.OOE-06 1.29E-06 4.29E-07 4.29E-07 4.29E-07 8.57E-06 U-234 2.84E-06 6.1OE-07 2.03E-07 2.03E-07 2.03E-07 4.06E-06 U-235 8.89E-07 1.91E-07 6.35E-08 6.35E-08 6.35E-08 1.27E-06 U-238 5.71E-06 1.22E-06 4.OSE-07 4.08E-07 4.08E-07 8.15E-06 1)
Material at Risk WD:2015:0598
Page 20 In this example, most of the structure can be demolished using the mechanical shearing method, but some walls will require both types of sawing, and there is large contaminated equipment to be removed. It is also anticipated that some structures will require processing with a hydraulic hammer. The rubble produced by the demolition will be moved from the demolition area to a processing area where the rubble will be sorted.
Finally, the sorted rubble will be loaded into containers, sealed and shipped to final storage. The methods described previously will be used to determine the demolition emissions.
For a mechanical shearing operation with water misting, the source term for that part of the demolition operation is found with Equation 4. The following example is presented for the Am-241 inventory given in Table 1.
STMechshear = MAR X 5.00E05 STMech Shear, Am-241 = 2.35E03 Ci X 5.00E05 STMech Shear, Am241 = 1.18E07 Ci When using a diamond wire saw, the source term for that part of the demolition operation is found with Equation 6. Assume the kerf is 1.0 centimeter (cm) wide and the slab produced is 91.40 cm by 91.40 cm (3 feet by 3 feet). Also assume 4 cuts are required, and all of the same length. The following example is presented for the Am-241 inventory given in Table 1.
= SME-OS x MAR x (Length of cuts)(width of kerf)
LJLUIJLUIL(2 W LI Area of slab
= c_np-nc )(
fl4F-fl4
)(
4(9 1.4 cm)(1 cm)
(91.4 cm) (91.4 cm)
STDiamond wire, STDiamond wire, Am-241 = 1.11E09 Ci When using a wall saw, the source term for that part of the demolition operation is found with Equation 7. Assume the kerf is 1.0 centimeter (cm) wide and the slab produced is 91.40 cm by 91.40 cm (3 feet by 3 feet). Also assume 4 cuts are required, and all of the same length. The following example is presented for the Am-241 inventory given in Table 1.
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Page 21 STwaii saw = 5.0E03 X MAR X (Length of cuts) (width of kerf)
Area of slab
= (W-fl x 1FRF-fl4 x 4(91.4 cm)(1 cm)
(91.4 cm) (91.4 cm)
STwa saw, STwaii saw, Am-241 = 3.70E-08 Ci For the segmentation of large equipment operation, the source term for that part of the demolition operation is found with Equation 9. The following example is presented for the Arn-241 inventory given in Table 1.
STse,qment
= MAR X 1.00E05 STsegmentjng, Am-241 = 1.68E04 Ci X 1.00E05 STsegment in,q, Am-241 = 1.68&09 Ci When using a hydraulic hammer, the source term for that part of the demolition operation is found with Equation 5. The following example is presented for the Am-241 inventory given in Table 1.
STHydraulic hammer = MAR X 1.00E03 STHydraulic hammer, Am-241 = 1.68E04 Ci X 1.00E03 STHydraulic hammer, Am-241 = 1.68E07 Ci The results of these calculations for each radionuclide in the facility inventory and for each demolition technique are presented in Table 2.
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Page 22 Table 2: Demolition operations emissions Releases Releases Releases Releases due Releases due to due to due to Demolition d ue Diamond Segmenting Hydraulic Total Radionuclide Mechanical Wall Saw Wire Saw Large Hammer Release Shearing Operations Operations Equipment Operations (Ci)
IC '
(C )
(Ci)
(Ci)
(Ci)
Am-241 1.18E-07 1.11E-09 3.70E-08 1.68E-09 1.68E-07 3.26E-07 Cm-243 1.57E-1O 1.48E-12 4.93E-11 2.24E-12 2.24E-1O 4.34E-1O Cm-244 3.94E-09 3.72E-11 1.24E-09 5.63E-11 5.63E-09 1.09E-08 Cs-137 2.1OE-05 1.98E-07 6.59E-06 3.OOE-07 3.OOE-05 5.80E-05 Ba-137m 2.1OE-O5 1.98E-07 6.59E-06 3.OOE-07 3.OOE-05 5.80E-05 1-129 3.47E-15 3.27E-17 1.09E-15 4.96E-17 4.96E-15 9.60E-15 Np-237 1.25E-11 1.18E-13 3.94E-12 1.79E-13 1.79E-11 3.46E-11 Pu-238 3.48E-08 3.28E-1O 1.09E-08 4.97E-1O 4.97E-08 9.63E-08 Pu-239 1.93E-08 1.82E-1O 6.06E-09 2.75E-1O 2.75E-08 5.33E-08 Pu-240 1.47E-08 1.39E-1O 4.62E-09 2.1OE-1O 2.1OE-08 4.07E-08 Pu-241 3.25E-07 3.07E-09 1.02E-07 4.65E-09 4.65E-07 9.OOE-07 Sr-90 2.54E-06 2.39E-08 7.98E-07 3.63E-08 3.63E-06 7.02E-06 Y-90 2.54E-06 2.39E-08 7.98E-07 3.63E-08 3.63E-06 7.02E-06 Tc-99 7.48E-1O 7.05E-12 2.35E-1O 1.07E-11 1.07E-09 2.07E-09 U-232 8.39E-1O 7.91E-12 2.64E-1O 1.20E-11 1.20E-09 2.32E-09 U-233 3.OOE-1O 2.83E-12 9.43E-11 4.29E-12 4.29E-1O 8.30E-1O U-234 1.42E-1O 1.34E-12 4,47E-11 2.03E-12 2.03E-1O 3.93E-1O U-235 4.45E-11 4.19E-13 1,40E-11 6.35E-13 6.35E-11 1.23E-1O U-238 2.85E-1O 2.69E-12 8.97E-11 4.08E-12 4.08E-1O 7.89E-1O The next step in the process is to move the rubble pile to a sorting area. This process is considered rubble handling. Emissions from rubble handling are determined with Equation II. The following example is presented for the total Am-241 inventory given in Table 1.
Typically, rubble piles will be processed when the wind are low, however as a bounding condition for this example assume a wind speed of 20 miles per hour (8.8 mIs). Also assume that the rubble piles are maintained wet at about 2% moisture and that fixative is applied. Therefore, the moisture factor is set to 3%.
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Page 23 (U/ 2)13 ST = MAR x 0.0016 (M/2) 1.4 STAm241 = 3.36E-03 Ci x (0M016 (8.8/)13 mCi/
(/2)'
Ci mCi'
\\
= 3.36E-03 Ci x( 5.50E-03
'Ci)
= (1.85 E-05 mCi)(103 Ct/mCi) = 1.85E-08 Ci The results of this calculation for each radionuclide in the facility inventory are presented in Table 3.
Table 3: Rubble hand/mM and sortinM emissions Rubble Handling Radionuclide Emissions (Ci)
Am-241 1.85E-08 Cm-243 2.46E-11 Cm-244 6.20E-10 Cs-137 3.30E-06 Ba-137m 3.30E-06 1-129 5.45E-16 Np-237 1.97E-12 Pu-238 5.47E-09 Pu-239 3.03E-09 Pu-240 2.31E-09 Pu-241 5.11E-08 Sr-90 3.99E-07 Y-90 3.99E-07 Tc-99 1.18E-l0 U-232 1.32E-10 U-233 4.71E-11 U-234 2.23E-11 U-235 6.99E-12 U-238 4.48E-11 WD:2015:0598 STAm 21 STAm241
Page 24 The next step is to process the rubble by sorting into piles of similar waste category.
Again this process is a rubble handling operation. The emission would be calculated with Equation II, as described above for moving the pile. Emissions resulting from this process would be the same as that presented in Table 3.
The final step is load the rubble in containers for shipment. Emissions from load out are determined with Equation 12. The following example is presented with the Am-241 inventory given in Table 1.
ST = MAR x 2.9E-05 STAm241 = 3.36E03 Ci X 2.9E05 STAm241 = 9.75E08 Ci The results of this calculation for each radionuclide in the facility inventory are presented in Table 4 Table 4: Load out emissions Load Out Radionuclide Emissions (Ci)
Am-241 9.75E-08 Cm-243 1.30E-1O Cm-244 3.27E-09 Cs-137 1.74E-05 Ba-137m 1.74E-05 1-129 2.87E-15 Np-237 1.04E-11 Pu-238 2.89E-08 Pu-239 1.60E-08 Pu-240 1.22E-08 Pu-241 2.69E-07 Sr-90 2.1OE-06 Y-90 2.1OE-06 Tc-99 6.20E-10 U-232 6.95E-1O U-233 2.49E-1O U-234 1.18E-1O U-235 3.68E-11 U-238 2.36E-10 WD:201 5:0598
Page 25 The total emissions from this demolition project are found as the sum of each process and are presented in Table 5.
Table 5: Emissions by process and as a total for the demolition ro/ect Moving Rubble Total Demolition Load Out Debris Sorting Demolition Emissions Emissions Radionuclide (Ci)
Emissions Emissions (CS)
Project (Ci)
(Ci)
Emissions (Ci)
[See Table 2]
[See Table 3]
[See Table 3]
[See Table 4]
Am-241 3.26E-07 1.85E-08 1.85E-08 9.75E-08 4.60E-07 Cm-243 4.34E-1O 2.46E-11 2.46E-11 1.30E-1O 6.13E-1O Cm-244 1.09E-08 6.20E-1O 6.20E-1O 3.27E-09 1.54E-08 Cs-137 5.80E-O5 3.30E-06 3.30E-06 1.74E-05 8.20E-05 Ba-137m 5.80E-05 3.30E-06 3.30E-06 1.74E-05 8.20E-05 1-129 9.60E-15 5.45E-16 5.45E-16 2.87E-15 1.36E-14 Np-237 3.46E-11 1.97E-12 1.97E-12 1.04E-1].
4.90E-11 Pu-238 9.63E-08 5.47E-09 5.47E-09 2.89E-08 1.36E-07 Pu-239 5.33E-08 3.03E-09 3.03E-09 1.60E-08 7.54E-08 Pu-240 4.07E-08 2.31E-09 2.31E-09 1.22E-08 5.75E-08 Pu-241 9.OOE-07 5.11E-08 5.11E-08 2.69E-07 1.27E-06 Sr-90 7.02E-06 3.99E-07 3.99E-07 2.1OE-06 9.92E-06 Y-90 7.02E-06 3.99E-07 3.99E-07 2.1OE-06 9.92E-06 Tc-99 2.07E-09 1.18E-10 1.18E-1O 6.20E-1O 2.92E-09 U-232 2.32E-09 1.32E-1O 1.32E-1O 6.95E-1O 3.28E-09 U-233 8.30E-1O 4.71E-11.
4.71E-11 2.49E-1O 1.17E-09 U-234 3.93E-10 2.23E-11 2.23E-11 1.18E-1O 5.56E-1O U-235 1.23E-1O 6.99E-12 6.99E-12 3.68E-11 1.74E-1O U-238 7.89E-1O 4.48E-11 4.48E-11 2.36E40 1.12E-09 The emissions determined by this method can now be modeled with CAP-88, or other approved dose calculation method, to determine the dose to the public or worker.
Although not part of this method, this step is performed below using unit dose conversion factors (UDCF). UDCFs are determined by modeling 1 curie of a radionuclide with a dose model. The resulting dose is of the form mrem/Ci and can be used in calculation of doses in spreadsheets. Table 6 presents the results of applying UDCF values to the total emissions from Table 5.
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Page 26 Table 6.' Dose estimation/or demolilion project Total Total Demolition UDCF Demolition Radionuclide Project (mrem/Ci)
Project Dose Emissions (mrem)
(Ci)
Am-241 4.60E-07 1.96E+02 9.02E-05 Cm-243 6.13E-1O 1.48E+02 9.07E-08 Cm-244 1.54E-O8 1.25E+02 1.93E-06 Cs-137 8.20E-05 6.26E+OO 5.13E-04 Ba-137m 8.20E-05 1.44E-O1 1.18E-05 1-129 1.36E-14 1.31E+O1 1.78E-13 Np-237 4.90E-11 1.09E+02 5.34E-09 Pu-238 1.36E-07 2.17E^02 2.95E-05 Pu-239 7.54E-08 2.36E+02 1.78E-05 Pu-240 5.75E-08 2.36E+02 1.36E-05 Pu-241 1.27E-06 4.25E+OO 5.40E-06 Sr-90 9.92E-06 1.06E+O1 1.05E-04 Y-90 9.92E-06 3.57E-02 3.54E-07 Tc-99 2.92E-09 3.81E+OO 1.11E-08 U-232 3.28E-09 4.73E+O1 1.55E-07 U-233 1.17E-09 1.80E+O1 2.11E-08 U-234 5.56E-1O 1.76E+O1 9.79E-09 U-235 1.74E-1O 1.58E+O1 2.75E-09 U-238 1.12E-09 1.46E+O1 1.63E-08 Total 7.89E-04 Sum mary Since demolition activities were not considered when 40 CFR 61, Appendix D was promulgated, the use of the alternative calculation method described above is preferred, as it more accurately estimates emissions from demolition activities.
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Page 27 References DOE 1994 Airborne Release Fractions/Rates and Respirable Fractions for Nonreactor Nuclear Facilities, DOE-HDBK-30 10-94, US Department of Energy, 1994, Reaffirmed 2013 EPA I 989a Background Information Document: Procedures Approved for Demonstrating Compliance with 40 CFR Part 61 Subpart I, EPA 520/1-89-001, US Environmental Protection Agency, 1989 EPA I 989b Appendix D to Part 61 - Methods for estimating Radionuclide Emissions, US Environmental Protection Agency, 1989 EPA 1992 Fugitive Dust Background Document and Technical Information Document For Best Available Control Measures, EPA-450/2-92-004, US Environmental Protection Agency, 1992 EPA 1995 Compilation of Air Pollutant Emission Factors, AP-42, US Environmental Protection Agency, 1995 EPA 2004 Methods for Estimating Fugitive Air Emissions of Radionuclides from Diffuse Sources at DOE Facilities, US Environmental Protection Agency, 2004 Hanford 2013 Hanford Site Air Operating Permit, Final Permit No 00-05-006, Renewal 2, Washington State Department of Ecology and Health, April 2013 OSHA 2009 Controlling Silica Exposure in Construction, OSHA 3362-05, Occupational Safety and Health Administration, 2009 Napier 2009 Analysis of Radioactive Releases during proposed Demolition Activities for the 224-U and 224-UA Buildings, PNNL-1 8332, Pacific Northwest National Laboratory, Richland, Washington.
Napier 2010 Analysis of Radioactive Releases during proposed Demolition Activities for the 224-U and 224-UA Buildings, PNNL-1 8332 Addendum, Pacific Northwest National Laboratory, Richland, Washington.
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