ML18029A071
| ML18029A071 | |
| Person / Time | |
|---|---|
| Issue date: | 01/17/2018 |
| From: | NRC/OCIO |
| To: | |
| Shared Package | |
| ML18029A053 | List: |
| References | |
| FOIA/PA-2017-0581 | |
| Download: ML18029A071 (13) | |
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New York State Department of Environmental Conservation Division of Solid & Hazardous Materials 50 Wolf Road, Albany, New York 12233-7250 Phone: 518-457-6934 Fax: 518-457-0629 MlchHI 0. Zlgata Commiltioner NOVO 7199
Dear Interested Party:
On October 15 and 16, 1996, the Department of Environmental Conservatic~1 completed its first quarterly analysis of landfill gas from the Browning-Ferris Industries' (BFI) Niagara Landfill on River Road in Tonawanda. Enclosed for your information is a copy of our report.
Niagara Landfill is nearing final closure. BF l has installed a system of wells and pipes to manage the gas produced as the solid waste decomposes. The gas is drawn by blowers from 34 wells to a flare, where it is burned to destroy air pollutants.
To address concerns that the landfill gas could contain higher than normal concentrations of radon-222, our staff sampled the gas and analyzed the samples for radon.
We found that the gas does not contain high concentrations of radon. The radon released through the flare will disperse within 50 yards of the stack. At that distance, the radon concentration in the exhaust will be less than the normal concentration of radon-222 in outdoor air. Any radiation dose to people will be minimal and less than one ten-thousandth of the radiation dose we recdve due to natural background radiation. The radon emissions from the flare are not a significant hazard to the environment or the public.
A second purpose of this sampling was to determine if the operation of the flare had changed the concentration of radon in the landfill gas. In February of this year, before the flare was operating, our staff sampled the gas in six of the gas wells, which were then venting directly to the atmosphere, under natural pressure. We found that the concentration of radon was in the same range that we would expect if the gas wells were in normal soil.
However, it was not possible to predict what effect the blowers would have on the concentration of radon in the gas. The results in the enclosed report answer that question.
The operation of the flnre has not substantially increased the concentation of radon in the landfill gas.
This Department will test the landfill gas at least quarterly, during this first year that the flare is in operation. We will send you the results of future testing.
Please call Paul J. Merges, Ph.D. (518-457-2225), Chief of our Bureau of Pesticides
& Radiation, if you have any questions.
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Mr. James Holler Ms. Maryann Hllilman Superintendent 28 Warren Drive Tonawanda City School District Tonawanda, Ne, '{ork 14150 202 Broad Street Tonawanda, New York 14150 Mr. Joseph Kovacs Northeastern Services 3380 Sheridan Dr. Suite 142 Mr. Michael J. Skoney Amherst, NY 14226 Board President City of Tonawanda School District 86 Clinton Street Mr. and Mrs. Frazer Eggert Tonawanda, New York 14150 125 Amsterdam Street Tonawanda, New York 14150-5461 Mr. Ronald P. Dom Mr. Jason R. Zdrojewski 101 D1 'op Avenue Engineering Department TonawuJ1da, New York 14150-7~43 City of Tonawanda 200 Niagara Street Tonawanda, New York 14150-1099 Dr. Karim Rimawi Ms. Nonna S. Kilber Director 113 Sharon Drive Bur. of Environmental Radiation Protection Tonawanda, New York 14150-5137 New York State Department of Health 2 University Plaza Albany, New York 12237 Mr. P~ter Tamawskyj Mr. Richard Tobe, Commissioner Browning-Ferris Industries Department of Environment & Planning 5600 Niagara Falls Boulevard County of Erie Niagara Falls, New York 14304 95 Franklin Street Buffalo, New York 14202 Ms. Katherine Tussing Ms. Renee Voyt 66 Summer Steet 5 M Pennit Coordinator Buffalo, New York 14209 Browning-Ferris Gas Services, Inc.
757 N. Eldridge (77079)
P.O. Box 3151 Houston, Texas 77253 Mr. William Watson Mr. Dennis Sollenberger 771 Fletcher Street Office of State Programs Tonawanda, New York 14150 U.S. Nuclear Regulatory Commission Mail Stop 3-D-23 Washington, DC 20555-000 I
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Mr. Carl J. Calabrese The Honorable Alice A. Roth Supervisor Mayor, City of Tonawanda Tonawanda Town Hall 200 Niag..Ja Street 2919 Delaware Avenue Tonawanda, New York 14150-1099 Kenmore, New York 14217 Mr. Paul B. Kranz Environmental Compliance Services Mr. Daniel Brousse Department of Environment & Planning 24 Stark Street County of Erie Tonawanda, New York 14150 95 Franklin Street Buffalo, New York 14202 The Honorable Charles M. Swanick Ms. Alexandra Cukan Legislator 10th District Sierra Club, Niagara Group Chair Erie County Legislature P.O. Box 591 3200 Elmwood Avenue, Room 115 Cheektowaga, New York 14255 Kenmore, New York 1421 Mr. Andrew Freedman Mrs. Jean Dutton Norton/Radin/Hoover/Freedman 49 Murray Terrace 2858 Delaware Avenue Tonawanda, New York 14150 Kenmore, New York 14217-2789 Mr. Paul A. Giardina Mr. Craig Gordon Chief, Radiation Branch U.S. Nuclear Regulatory Commission U.S. Environmental Protection Agency Region 1 Region II 475.Allendale Road 290 Broadway, 21st Floor King of Prussia, PA 19406 New York, NY 10007-1866 Dr. Michael H. Surgan Chief Scientist Ms. Verna Gross Environmental Protection Bureau 342 Young Street Office of New York State Attorney General Tonawanda, New York 14150 120 Broadway New York, New York 10271 Mr. Gary H. Bauer Ms. Moria Henderson 22 Newel Apt. 6 743 Fletcher Street Tonawanda, New York 14150 Tonawanda, New York 14150
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uranium ore residues processed during the Manhattan Engineering District (MED) project were excavated from the Ashland 1 Site, which is adjacent to the Niagara Landfill, and relocated onto the Niagara Landfill Site in three areas identified as Areas A, B, and C (see Figure 2). Area A is the largest, covering about 10 acres. A fourth area, Area D, also contains MED waste. It is continuous with an area of contamination on the Ashland 1 site.
The DOE has est~red that there are 91,100 cubic yards of FUSRA.P material in Areas A and D and another 25,900 cubic yards of FUSRAP material in Areas B and C. At some point in time, the 2 acres in Areas Band C were covered with about 20 - 40 feet of refuse.
Gas Extraction System The Niagara Landfill has 34 methane extraction well:, (see Figure 3), which are collectively routed through a blower unit to a flare. Figure .., shows the location of each of the 34 gas wells. BFI had originally designed the gas extraction system to cover the entire landfill. At DEC's recommendation, BFI deleted from the original plans four wells that would have been located near the contaminated soil. Thus, none of the wells in the gas extraction system collect gas directly from the FUSRAP material.
Samplina Procedure In order to measure the radon release from the landfill, a plan was developed for sampling the radon in the gas pipe line after (i.e., downstream ot) the blower and prior to (i.e., upstream ot) the flare. Figure 5 shows the relationship of the sampling port to the rest of the system.
To take a sample, first a fitting was installed into the sample port and tygon tubing was connected to the fitting. The sampling train then consisted of an inline paper filter, a drierite cartridge, the Lucas cell and finally the 5 liter/minute air pump, all connected together using tygon tubing. Gas was pumped through the Lucas cell for five minutes to flush all of the high purity nitrogen out of the Lucas cell and replace it with landfill gas.
(Note: high purity nitrogen is routinely used to flush out the cell after use.)
In the planning stages for this sampling event it was decided that a minimum of three samples would be required to make a determination of the radon concentration. In addition to our samplinr. BFJ arranged to have Wilkes University analyze three samples as well. On the afternoon 01 October 15, 1996, Bureau collected three landfill gas samples in our Lucas cells and three landfill gas samples in Lucas cells owned by Wilkes University. Wilkes University samples were collected alternately with ours. After the sampling was completed, DEC staff packaged and delivered the Wilkes University samples to Airborne Express for shipment to Wilkes University.
On the morning of October 16, 1996, DEC staff filled three more of the Bureau's Lucas cells to see if there was any variation of radon concentration with time of day. After sampling, Bureau staff returned to Albany with all six Lucas c:lls for analysis. A minimum Page 2 of 5
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< I I ' ! I l c ' ' ' I ' < .' \' ! t ' I New York State Department of Environmental Con1ervatlon Division of Solid & Hazardous Materials Bureau of Pesticides & Radiation 60 Wolf Road, Albany, New York 12233-7265 618-467-2225 FAX 518-486-8390 Michael D. Z.g1ta Commls1ioner Niagara Landfill Gas Extraction System First Quarterly Sampling and Evaluation of Radon Releases October 15-16, 199r by J. Mitchell, W. Tetley, P.E., and B. Youngberg November 7, 1996 SummaO' Bureau of Pesticides & 'adiation staff collected six samples of landfill gas from the Niagara Landfill on October 15 & 16, 1996. These samples of landfill gas were collected from a sampling port located in the piping lear *ng from the blower to the flare before the flame arrestor. Radon concentrations showed litt!e variation over time. Mathematical models predict that the radon disperses to background concentrations within 40 meters of L'ie stack. Annual a, *erage radon concentrations ,,
- ground level would be indistinguishable from background.
History of Site The Niagara Landfill is located in the Town of Tonawanda, Erie County (Figure 1).
The site was an operating landfill in 1978 when Part 360 went into effect. Niagara Landfill, a subsidiary of Browning-Ferris Industries (BFI), operated the facility under NYSDEC Permit No. 9-1464-00147/00001-0. The land itself is ow:ed by Seaway Industrial Development, Inc. The landfill ceased accepting waste in 1993 and is now undergoing closure. As pan of closure operations, 6 NYCRR Part 360 requires a landfill gas venting system to be installed. At present, the landfill gas is actively being pumped to a flare system authorized under NYSDEC permit No. 9-0464-00184/00001.
The Niagara Landfill is one of the four properties designated as the Tonawanda Site by the United States Department of Energy (DOE) under the DOE's Formerly Utilized Sites Remedial Action Program (FUSRAP). The Niagara Landfill Site comprises approximately 100 acres located in an industrialized area in nonhwestem Tonawanda, New York. In 1974, Page 1 of S
high as 299 pCi/1, but some of those results are probably in error, due to the different instruments used.) The range in the samples collected in October is 175 to 194 pCi/1. The two ranges overlap. The October samples were in effect drawn from all 34 wells, so detailed comparisons between the two data sets cannot be made. However, it is apparent that the operation of the flare has not substantially increased the concentration of radon in the landfill gas.
Impacts of Radon Emissions from the Flare The concentration of radon in the emissions will be reduced by at least an order of magnitude due to the high volume of the exhaust flow. The landfill gas 1..ontains radon at about 200 pCi/1 and flows to the flare at 1200 cubic feet per minute. The exhaust leaves the stack at about 52,000 cubic feet per minute. The increase in flow rate is due to combustion air (which enters the flare stack through louvers in the side of the stack) and the heating of the exhaust gasses (the temperature of the exhaust is 1400 degrees F). As a result of the higher outflow, the concentration of radon in the stack will be on the order of 10 pCi/1 (in addition to the natural background radon in the air drawn into the stack through the louvers).
The impacts of the measured radon emissions were assessed using three Gaussian plume models: US Environmental Protection Agency's SCREEN3 model, DEC's Air Guide 1 model, and the US Environmental Protection Agency's CAP88. Inputs for the models were selected to be conservative; therefore, actual impacts will less than those predicted by the models.
SCREEN3 was used to assess the dispersion of the radon after release. SCREEN3 calculates the hourly average concentration of a pollutant at various distances from the stack.
It was used only to estimate the distance from the flare stack at which the concentration of radon in the plumr. falls within the range of natural background concentrations of radon (i.e., 0.1 to 0.5 pCi/1). The model was run six times, under '1 full range of meteorological conditions. In all cases, the model predicted that the concentration of radon in the plume W(}Uld fall below O.S pCi/1 within 20 meters of the stack, and below 0.1 pCi/1 within 40 meters. Under the more favorable meteorological conditions, the model calculates a radon concentration less than 0.5 pCi/1 within 10 meters of the stack and less than 0.1 pCi/1 within 20 meL..!rs. Screen3 was used only to estimate ti:~ dispersion of the radon near the stack.
DEC's Air Guide l model calculates a worst-case annual average concentration of a pollutant, based on the emission rate and meteorological data from the past five years. In this case, the meteorological data from the Buffalo International Airport was used. The model was used to predict the maximum annual average concentration of radon at ground level due to emissions from the flare. The result was 0.0001 pCi/1, which is less than 0.1 %
of natural radon concentrations. This concentration would be indistinguishable from background concentrations of radon.
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of four hours between sampling and analysis is required to allow for equilibration. Since the travel time from Buffalo to Albany is about 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, this was not a problem. Bureau staff analyzed the samples for radon on October 16 and 17, 1996.
Results of Analysis The samples were analyzed by the Bureau on our instrumentation, which consists of a Ludlum Model 182 Radon Flask Counter connected to a Ludlum 2000 Portable Scaler. The following table gives the analysis results (decay corrected to the time the gasses were extracted from the sampling *'t):
Lucas Cell No. Sar1 'ing Date r Radon Concentration (pCi/1) 1194 10/15/96 194 +/- 3.5 1203 10/15/96 190 +/- 3.4 1199 10/15/96 193 +/- 3.5 1198 10/16/96 175 +/- 3.2 1193 10/16/96 192 +/- 3.5 1197 10/16/96 184 +/- 3.5 Discussion The average radon concentration of the samples collected on the afternoon of October 15 was 192 pCi/1. The average concentration of the samples collected on the morc*ng of October 16 was 184 pCi/1. The difference between the two averages is >>mall (4%). For evaluating the impacts of the radon emissions, a concentration of 200 pCi/1 was used.
~omparison to Previous Result§ In February 1996. before the flare was operating, DEC sampled the gas in six or the gas wells, which were then venting directly to the atmosphere, under natural pressure. The results are presented in DEC's March 20, 1996 report. That report acknowledged that the operation of the flare could change the concentration of radon in the landfill gas, but also stated that the effect could be determined only by analyzing the gas once the flare was in operation. One purpose of the October 1996 sampling was to begin to answer th~~ question.
The concentration of radon in the six wells sampled in February ranged from 87 to 193 pCi/1. (Those results were obtained when the Lucas cells were counted on DEC's imtnunents. A contractor lab also counted the same Lucas cells and found concentrations as Page 3 of 5
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A third model, CAP88 was used to assess the radiation dose a member of the general public could receive due to the radon emissions from the flare. CAP88 calculates the maximum radiation dose to a member of the general public using historical meteorological data. CAP88 was run three time~, each time with a different set of meteorological data.
The data sets used were from the Buffalo International Airport (in Cheektowaga), the City of Buffalo, and Niagara Falls. To simulate extreme, adverse conditions, the mixing height was fixed at 26 meters, or about twice the height of the stack, for the entire year. The effect is that the model mixes the plume only in the layer of air between ground level and an elevation of 26 meters. Mixing heights are usually on the order of hundreds of meters. A low, fixed mixing height cannot occur at the site, so the modeling results represent a radiation dose that no person will receive from this emission point. The dose is an extreme upper bound to the range of possible radiation doses due to this radon emission. The predicted maximum ground level concentration of radon was O 0005 pCi/1 (less than 0.1 % of natural radon concentrations). This corresponds to a worst-case annual radiation dose of 0.01 millirem per year. This projected dose is less than 0.0001 of the dose due to background radiation.
The results from all three models confirm that the radon emitted from the flare will disperse within .: short distance of the flare and at ground level will be indistinguishable from the radon naturally present in the air. Any radiation dose to the public will be minimal and well within the nonnal range of doses due to background radiation.
C2°'lusions
- 1. The radon released through the flare disperses to a concentration indistinguishable from background radon concentrations within 40 meters of the stack.
- 2. The projected maxin.am radiation dose due to the radon emissions is less than 0.01 mrem/year and less than 0.0001 of the dose due to natural background radiation.
- 3. There is no adverse effect on the environment or the public health and safety from the emission of radon from the landfill. *
- 4. There is a small difference in the radon concentrations in gas samples collected in the afternoon compared to those collected in the morning.
Future Actions The Bureau will continue to perfonn quarterly monitoring during the first year of operation of the flare.
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