ML20206N173

Environ Assessment of Bmi Vol Reduction Demonstration Facility in West Jefferson,Oh

ML20206N173
Person / Time
Site:	07000008
Issue date:	06/30/1986
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
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ML20206N165	List: ML20206N159 ML20206N173 ML20206N185
References
NUDOCS 8607010393
Download: ML20206N173 (80)

Text

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,f U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS 1

ENVIRONMENTAL ASSESSMENT OF -

BATTELLE COLUMBUS LABORATORIES VOLUME REDUCTION DEMONSTRATION FACILITY WEST JEFFERSON, OHIO (DOCKET 70-8)

JUNE 1986 4

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TABLE OF CONTENTS Section Page LIST OF TABLES.................... .................................... vii 1

LIST OF FIGURES........................................................ vii

1. 0 INTRODUCTION...................................................... 1-1

1.1 DESCRIPTION

OF PROPOSED ACTI0N............................... 1-1

1. 2 INTERACTION WITH THE PUBLIC AND STATE AND LOCAL GOVERNMENTS.................................................. 1-1

1. 3 RELATED DOCUMENTATION........................................ 1-2 1.3.1 NRC Environmental Impact Assessment................... 1-2 1.3.2 Existing BCL License.................................. 1-2 1.3.3 Topical Reports....................................... 1-2 1.3.4 BCL Analyses.......................................... 1-2 1.3.5 NRC Safety Evaluation of the VR0F..................... 1-2

1. 4 ORGANIZATION OF REP 0RT....................................... 1-3

1. 5 REFERENCES................................................... 1-3

2.0 DESCRIPTION

OF THE SITE ENVIR0'NMENT............................... 2-1 2.1 SITE LOCATION................................................ 2-1 2'. 2 DEM0 GRAPHY................................................... 2-1

2. 3 LAND USE..................................................... 2-5 2.4 GE0 LOGY...................................................... 2-5 2.5 HYDR 0 LOGY.................................................... 2-6 2.5.1 Surface Water......................................... 2-6 2.5.2 Surface Flooding Potentia 1............................ 2-6 2.6 METEOROLOGY AND CLIMAT0 LOGY................................... 2-7

2.7 BACKGROUND

RADIOLOGICAL CHARACTERISTICS...................... 2-7 2.8 EC0 LOGY...................................................... 2-8 2.8.1 Terrestrial Ecology................................... 2-8 l 2.8.2 Aquatic Ecology....................................... 2-8 -

2.9 REFERENCES

................................................... 2-9 i

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• O TABLE OF CONTENTS (Continued)

Section Page 3.0 THE FACILITY...................................................... 3-1 3.1 EXTERNAL APPEARANCE.......................................... 3-1 3.2

SUMMARY

OF OPERATIONS / PROCESSES.............................. 3-1 3.2.1 Receipt of LLW........................................ 3-1 3.2.2 Preprocess Staging and Storage........................ 3-1 3.2.3 Incineration.......................................... 3-3 3.2.3.1 Incinerator.................................. 3-3 3.2.3.2 Process Gas Cleanup System................... 3-3 3.2.3.3 Ash-Handling System.......................... 3-3 3.2.3.4 Shipment of LLW Ash.......................... 3-5 3.3 TRANSPORTATION TO AND FROM THE FACILITY...................... 3-5 3.3.1 Routes................................................ 3-5 3.3.2 Shipping Methods...................................... 3-5

3.4 REFERENCES

................................................... 3-6 4.0 CHARACTERIZATION OF INCOMING WASTE AND VROF END-PRODUCT........... 4-1 4.1 CHARA'CTERIZATION OF INCOMING WASTE........................... 4-1 4.1.1 Waste Generators and Characteristics.................. 4-2 4.1.1.1 Nuclear Power Plants......................... 4-2 4.1.1.2 Institutional Facilities..................... 4-2 4.1.1.3 Industrial Facilities........................ 4-2 4.1.1.4 Hazards...................................... 4-2 4.1.2 Waste Volumes......................................... 4-3 4.1.2.1 Incoming Waste Volumes Used in Environmental Assessment..................... 4-3 4.1.2.2 Reactor Waste................................ 4-3 4.1.2.3 Industrial and Institutional Waste........... 4-4 4.2 CHARACTERIZATION OF VRDF END-PRODUCT......................... 4-5

4.3 REFERENCES

................................................... 4-5 5.0 WASTE CONFINEMENT AND EFFLUENT CONTR0L............................ 5-1 5.1 WASTE CONFINEMENT............................................ 5-1 5.1.1 Receipt of LLW Materia 1............................... 5-1 5.1.2 Preprocess Staging and Storage....................... 5-1 5.1.3 Waste Loading......................................... 5-1 5.1. 4 Incinerator 0peration................................. 5-2 111

o TABLE OF CONTENTS (Continued)

Section Page 5.1. 4.1 Incineration................................. 5-2 5.1.4.2 Off-Gas Treatment............................ 5-3 5.1.4.3 Ash Handling................................. 5-4 5.1. 5 Post-Process Staging.................................. 5-5 5.1. 6 Administrative Controls............................... 5-5 5.1.6.1 VRDF Area Controls........................... 5-5 5.1.6.2 Inventory Contro1............................ 5-6 5.2 EFFLUENT CONTR0L............................................. 5-6 5.2.1 Gaseous Effluents..................................... 5-6

5. 2.1.1 Waste Loading................................ 5-7 5.2.1.2 Incinerator.................................. 5-7 5.2.1.3 Ash Handling................................. 5-7

5. 2.1. 4 Compensating Vesse1.......................... 5-7 5.2.1.5 Ventilation System........................... 5-7 5.2.2 Liquid Effluents...................................... 5-9 -

• 5. 2. 2.1 Process Water................................ 5-9 5.2.2.2 Drains and Sewage System..................... 5-9 5.2.2.3 Laundry...................................... 5-10 5.2.3 Solid Wastes.......................................... 5-10

5.3 REFERENCES

................................................... 5-10 6.0 ENVIRONMENTAL EFFECTS OF NORMAL FACILITY OPERATIONS AND TRANSPORTATION.................................................... 6-1 6.1 RADIOLOGICAL EFFECTS FROM OPERATIONS......................... 6-1 6.1.1 Airborne Eff1uent..................................... 6-1 6.1. 2 Liquid Effluents...................................... 6-4 6.1. 3 Radiation Exposure to Workers......................... 6-4 6.1.4 Radiation Exposure to the Population.................. 6-4 6.1. 5 Transportation........... ............................ 6-5 6.1.5.1 Radiological Impacts......................... 6-5 6.2 PONRADIOLOGICAL IMPACTS...................................... 6-6 6.2.1 Site Preparation and Construction..................... 6-7 6.2.2 Facility Operations................................... 6-7 iv

TABLE OF CONTENTS (Continued)

Section Page 6.2.2.1 Operational Releases to the Atmosphere....... 6-7 6.2.2.2 Operational Effects on the Terrestrial Environment...................... 6-8 6.2.2.3 Operational Effects on the Aquatic Environment.......................... 6-8 6.2.2.4 Social and Economic Effects.................. 6-8 6.3 IMPACTS ON LAND USE.......................................... 6-8 6.4 IMPACTS ON WATER USE......................................... 6-8 6.5 DECOMMISSIONING.............................................. 6-8 6.6 ' REFERENCES................................................... 6-9

7. 0 DESCRIPTION OF OCCUPATIONAL AND ENVIRONMENTAL MONITORING PR0 GRAMS.......................................................... 7-1 7.1 OCCUPATIONAL MONITORING PR0 GRAM.............................. 7-1 7.1.1 Personnel Monitoring.................................. 7-1 7.1. 2 Contamination Surveys................................. 7-1 7.1. 3 Radiation Monitoring.................................. 7-2

'7.2 MONITORING OF EFFLUENTS TO ATMOSPHERE........................ 7-2 7.2.1 Stack Monitoring...................................... 7-2 7.2.2 Environmental Monitoring Program...................... 7-2

7.3 REFERENCES

................................................... 7-2 8.0 IMPACT OF POTENTIAL ACCIDENTS IN FACILITY OPERATIONS AND TRANSPORTATION................................................ 8-1 8.1 INTR 000CTION................................................. 8-1 8.2 EVALUATION OF POTENTIAL ENVIRONMENTAL AND OCCUPATIONAL IMPACTS OF ACCIDENTS......................................... 8-1 8.3 INCINERATOR.................................................. 8-1 8.3.1 Incinerator Explosion................................. 8-2 8.3.1.1 Radiological Effects......................... 8-2 8.3.1.2 Comparison to BCL EA Accident Analysis....... 8-3 8.4 WASTE STORAGE AREA FIRE...................................... 8-3 8.4.1 Radiological Effects.................................. 8-3

. 8.4.2 Comparison to BCL EA Accident Analysis................ 8-3 8.5 CONTAINER RUPTURE............................................ 8-8 v

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TABLE OF CONTENTS (Continued) i Section Page 8.5.1 Radiological Effects.................................. 8-8 8.5.2 Comparison to BCL EA Accident Analysis................ 8-8 8.6 TRANSPORTATION ACCIDENT...................................... 8-8 8.7 LOSS-O F- POWER ACC ID ENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8-11

8.8 REFERENCES

................................................... 8-11 9.0 DISCUSSION OF WASTE MANAGEMENT 0PTIONS............................ 9-1 9.1 CONTINUE PRESENT PRACTICES................................... 9-1 9.2 VOLUME REDUCTION BY MATERIAL GENERATOR....................... 9-1 9.3 VOLUME REDUCTION AT EXISTING DISPOSAL SITES.................. 9-2 9.4 BUILD THE VRDF WITH A HIGH-FORCE COMPACTOR 0NLY.............. 9-2 9.5 ALTERNATIVE VOLUME REDUCTION METH0DS......................... 9-3 9.6 EVALUATION OF ALTERNATIVES................................... 9-3

9. 7 REFERENCES................................................... 9-3 10.0

SUMMARY

AND CONCLUSION OF ENVIRONMENTAL IMPACTS OF CONSTRUCTION AND 0PERATIONS.......................................

10-1 10.1

SUMMARY

OF THE ENVIRONMENTAL EFFECTS OF THE VRDF............. 10-1 10.2 NRC STAFF FINDINGS........................................... 10-1

10.3 REFERENCES

................................................... 10-3 APPENDIX A A. DIOXIN AND ITS RELATIONSHIP TO INCINERATOR EMISSIONS. . . . . . . . . . . . . . A-1 A.1 INTR 000CTION................................................. A-1 A.2 DESCRIPTION OF DI0XIN........................................ A-1 A.3 T0XICITY..................................................... A-1 A.4 PERMISSIBLE CONCENTRATIONS OF DI0XIN......................... A-2 A.5 MECHANISMS FOR FORMATION OF DIOXIN DURING INCINERATION....... A-2 A. 5.1 General Mechanisms.................................... A-2 A.S.2 Mechanisms for Dioxin Formation During Incineration... A-3 A.S.3 Location of Formation of Dioxin. . . . . . . . . . . . . . . . . . . . . . . A-4 A.5.4 Variables Affecting Formation of Dioxin During Incineration.......................................... A-4 A.5.4.1 Feedstock.................................... A-4 A.5.4.2 Incinerator Operating Conditions............. A-4 A.6 EMISSIONS CONTROL FOR DIOXIN AT THE VRDF. . . . . . . . . . . . . . . . . . . . . A-5 A.7 ANALYSIS METH0DS............................................. A-6 A.8 CONCLUSIONS.................................................. A-6 A.9 REFERENCES................................................... A-7 vi

TABLE OF CONTENTS (Continued)

Table Page 2.1 Population Distribution Around the BCL Site in 1980............... 2-4 2.2 Annual Average Relative Concentrations for the BCL Site........... 2-8 2.3 Fifty Percentile Short-Term (2-hr) Relative Concentrations for the BCL Site................................................ 2-9 4.1 Projected Isotopic Concentrations in Reactor Waste................ 4-4 4.2 Projected Isotopic Concentrations in Industrial and Institutional Waste...........................................................

6.1 Annual Curie Content of Input to 4-5

' Incinerator...................... 6-2 6.2 Annual Incinerator Releases from Combined Waste Input............. 6-3 6.3 Maximum Concentrations of Radionuclides at Ground Level from Normal VROF Operations..................................... 6-3 6.4 Annual Dose to Maximum Individual Offsite from Normal Operations...................................................... 6-6 6.5 Comparison of Primary Annual Mean Air Quality Standards. . . . . . . . . . . 6-7 8.1 Summary of Whole Body Dose to Maximally Exposed Individual from Various Accident Scenarios....................................... 8-2 8.2 Whole Body Dose to Maximally Exposed Individual from Incinerator Explosion (Reactor).............................................. 8-4 8.3 Whole Body Dose to Maximally Exposed Individual from Incinerator Explosion (Institutional)........................................ 8-5 8.4 Whole Body Dose to Maximally Exposed Individual from Fire in Waste Storage Building (Reactor)....................................... 8-6 8.5 Whole Body Dose to Maximally Exposed Individual from Fire in Waste Storage Building (Institutional)................................. 8-7 8.6 Whole Body Dose to Maximally Exposed Individual from Ash Container Rupture (Reactor)................................................

8.7 Whole Body Dose to Maximally Exposed Individual from Ash Container 8-9 Rupture (Institutional).......................................... 8-10 8.8 Whole Body Dose to Maximally Exposed Individual from Loss-of-Power Accident (Reactor)............................................... 8-12 8.9 Whole Body Dose to Maximally Exposed Individual from Loss-of-Power Accident (Institutional)......................................... 8-13 Figure 2.1 BCL West Je f ferson Facili ty Location. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 2.2 Location of Proposed Incinerator at Battelle's West Jefferson Nuclear Sciences Area........................................... 2-3 3.1 Plan View of the Volume Reduction Demonstration Facilit 3-2 3.2 Schematic of Incinerator Process.......................y.......... ........... 3-4 5.1 VROF Ventilation Schematic........................................ 5-8 vii

1.0 INTRODUCTION

In its October 1981 Policy Statement on 10w-level radioactive waste (LLW) volume reduction, the NRC encouraged licensees to reduce the volume of waste and limit the quantities of waste produced. In addition, in January 1986 amendments to the.1980 Low-Level Radioactive Waste Policy Act (Public Law 96-573) were adopted. An important aspect of the amendments is the economic incentive for reduction in the overall volume of waste shipped to the disposal sites. The following is an Environmental Assessment of a proposed volume reduction demon-stration facility (VRDF) to be located in Central Ohio. Volume reduction will be accomplished by incineration. The purpose of the program is to demonstrate the safety, technical effectiveness, and cost effectiveness of incineration as a method of low-level radioactive waste management.

1.1 Description of Proposed Action Battelle-Columbus Laboratories (BCL) maintains and operates permanent nuclear facilities for conducting research programs using special nuclear and byproduct materials. The facilities are located at two sites: 505 King Avenue, Columbus, Ohio; and West Jefferson, Ohio, about 17 miles west. of Columbus. The vast majority of SNM and byproduct materials handling and processing is conducted at the Nuclear Sciences Area located at the West Jefferson site: The King Avenue site accommodates laboratory-scale unirradiated U-235 activities (maximum 500 g),

and small quantities of byproduct material processing. On August 15, 1983; Battelle requested an amendment to Materials License No. SNM-7 to authorize LLW incinerator operations at their West Jefferson, Ohio, site. The operations would include receipt, volume reduction, storage, and shipment of LLW supplied under terms of negotiated contracts by utilities from their nuclear power plants, by universities, and possibly by institutions (hospitals, etc.). Radioactive, non-transuranic (TRU) waste from Battelle's nuclear and medical research opera-tions will also be treated in the facility.

1.2 Interaction with the Public and State and Local Governments The NRC staff has visited the West Jefferson site and surrounding area. During the visit they met with the Ohio Environmental Protection Agency who has jurisdiction over the non-radioactive emissions in Ohio and must grant a permit to' install new sources of pollution. Battelle had previously applied to Ohio EPA for a " Permit to Install" but has withdrawn the request. The reason for application withdrawai involved the termination clause of the Ohio Administrative -

Code (OAC) Section 3745-31-06. That section of the code terminates a permit to install if, within eighteen months from the permit date, the operator has not entered into a binding contractual obligation to complete installation. Because of the uncertainty of permit and licensing review schedules Battelle opted to withdraw their application rather than take the risk of expiration. The staff informed OEPA of our obligation to write an environmental assessment (EA) before taking licensing action and promised to provide a copy of the EA to Ohio EPA preliminary to Batte11e's reapplication for permit to install.

BCL has been engaged in public awareness activities in connection with the pro-posed demonstration incinerator.1 These activities included a news release, 1-1

printed in the Columbus Disoatch, that described the incinerator program. The news release prompted primary media stories that appeared in several local papers that dealt with community concerns and Battelle's efforts to provide information to ease these concerns. In addition Battelle has briefed the Ohio House Repre-sentative for Franklin County and the West Jefferson Mayor and councilmen on the proposed incinerator program. Community meetings have also been held to provide community awareness and answer community questions. These included public meetings with the Darby Estates Civic Association, the West Jefferson Community and Businessmen's Association, and the London (Madison County) Rotary Club.

1. 3 Related Documentation In order to evaluate the environmental effects of the proposed operations, a number of documents were used. A short discussion of the major resources follows.

1.3.1 NRC Environmental Impact Assessment In February 1981, the NRC caused to have prepared an Environmental Impact Assessment of the Battelle-Columbus operations.2 This document was used as the basis for the description of the site and surrounding environment (Section 2).

1.3.2 Existing BCL License All operations at Battelle-Columbus Laboratories (BCL) would be performed under the " umbrella" of the existing license. This license describes the plant speci-fications and controls (technical specifications, administrative policies and procedures, reviews, audits, training, safety, quality assurance, security, etc.). It also lists personnel organization, a description of plant activities, a decommissioning plan, and other plant activities.

1.3.3 Topical Reports The incinerator to be used at the BCL is a larger scale version of a prototype incinerator developed by Kernforschungsanstalt Juelich GmbH and Kraftanlagen AG Heidelberg a who are represented in the U.S. by ATCOR Engineered Systems, Inc.4 Topical reports by these organizations provided the basis for parts of Sections 3 and 6 of this EIA.

1.3.4 BCL Analyses BCL supplied, with the August 15, 1983 request for license amendment, several appendices to their license application. These appendices included safety re-lated information5 and an environmental assessment 8 relative to the VRDF. These documents were used, in conjunction with the aforementioned topical reports, as bases for description of facility operations (Section 3), waste confinement and effluent control methods (Section 5), and environmental monitoring equipment (Section 7).

1.3.5 NRC Safety Evaluation of the VRDF The NRC has prepared a Safety Evaluation of the VRDF. It will be used in con-junction with this EA to determine whether to amend the BCL license to include VRDF activities.

1-2

o .

1.4 Organization of Report The environment of the West Jefferson site and the surrounding area is discussed in Section 2. The VRDF facility, equipment, and operation are described in Section 3. Section 4 discusses the characteristics of incoming waste, and Sec-tion 5 describes waste confinement in the VRDF. Section 6 analyzes the environ-mental effects of normal VROF operations and transportation. Section 7 describes the environmental and occupational monitoring programs at the VRDF. The envi-ronmental effects of potential accidents are analyzed in Section 8. Section 9 discusses waste' management options and Section 10 lists the NRC staff's summary and conclusions. Appendix A presents a discussion of dioxin and its relationship to incinerator emissions.

1.5 References

1. Public Awareness Activities Summary with Attached News Release by Battelle Columbus Laboratories, dated November 18, 1982.

2. Environmental Impact Assessment, Battelle Memorial Institute Laboratory, Columbus, Ohio, Report No. SAI 81-307-WA, prepared for U.S. Nuclear Regulatory Commission, February 2,1981.

3. Incineration of Radioactive Wastes Applying the "Juelich Incineration Process," Manfred Wilke and Klaus Fatho, Heidelberg, April .1981.

4. ATCOR/Kraftenlagen Controlled Air Pyrolysis Incinerator, Kenneth H. Dufrane and Manfred Wilke, presented at ANS Topical Meeting on Treatment and Hand-ling of Radioactive Waste, April 1982, Hanford, Washington.

5. Report on Safety Related Information for the Battelle Volume Reduction Demonstration Facility, Battelle Columbus Laboratories and ATCOR Engineered Systems, Inc., April 15, 1983 (Appendix G to Renewal Application BCL-1081).

6. Report on Environmental Assessment for Demonstratinn Incineration Operations, Battelle Columbus Laboratories, August 15, 1983. (Appendix H to Renewal Application BCL-1081) 1-3

I i

2.0 DESCRIPTION

OF THE SITE ENVIRONMENT The proposed VROF M to be located on Battelle's West Jefferson property. The West Jefferson site. is described thoroughly in an NRC Environmental Impact Assessment 1, NUREG-08932, and BCL-1081, Appendix G.a These three documents and contained references are the basis for this section which briefly describes the site location, demography, land use, geology, hydrology, meteorology, clima-tology, background radiological characteristics, and ecology.

2.1 Site Location The West Jefferson site is located at 39* 58'N, 83* 15'W approximately 13 stat-ute miles west of the BMI King Avenue Facility (Figure 2.1). The West Jefferson site consists of a 1,000 acre tract which accommodates the Engineering Area in the southeastern portion, the Experimental Ecology Area in the east central portion and the Nuclear Sciences area in the northern portion. The northern boundary of the site lies approximately one mile south of Interstate Highway 70 and extends from the Georgesville-Plain City Road eastward to the Big Darby Creek. The eastern boundary of the site roughly parallels the valley of the Big Darby Creek southward to the Conrail tracks which constitute the southern boundary. The Georgesville-Plain City Road defines the western boundary of the site. The proposed incinerator facilities are to be located in the Nuclear Sciences Area as shown in Figure 2.2.

2.2 Demography The area immediately adjacent to the West Jefferson site has a low population density. Table 2-1 shows the population distribution, by direction and dis-tance, within 80 km (50 mi) of the site. Residences nearest the Nuclear Sciences Area are two houses that are located about 750 m (2500 ft) to the northwest and southwest, respectively. A Girl Scout camp, Camp Ken Jockety, is located on a bluff on the east side of Big Darby Creek at a distance of 450 m (1500 ft). On the east side of Big Darby Creek and 1.2 km (4000 ft) to the southeast, is the Lake Darby Estates residential subdivision. A total of 3000 people reside in Darby Estates. A second subdivision, West Point, east of the Lake Darby Estates and Hubbard Road, is considered a part of Darby Estates and the residents are included in the 3000 person total previously stated.

During the last 25 years, two major highways, I-70 and I-270, have been com-pleted near the West Jefferson site. The area around the junction of these highways, which is about 16 km (10 mi) east of the Nuclear Sciences area, has proven to be popular for industrial growth. It is estimated that the indus-trial population has shown an increase equivalent to that of the general popula-tion in this area, i.e., two and one-half times the population within 16 km (10 mi) in 1965. Most of the growth has taken place near the outer limits of -

Columbus; however, larger employers, e.g. General Motors and White-Westinghouse, have actually reduced their numbers of employees.

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Figure 2.2 Location of proposed incinerator at Batte11e's West Jefferson Nuclear Sciences area

Table 2-1 Population distribution around the BCL site in 1980 Oistance (km)

Sector 0-1.6 1.6-3.2 3.2-4.8 4.8-6.4 6.4-8 8-16 16-32 32-48 48-64 64-80 N 8 6 30 80 105 3,241 2,538 3,692 19,232 38,558 NNE 4 6 30 80 105 1,304 5,358 20,947 7,461 11,290 NE 2 6 30 80 105 3,310 4,405 7,734 6,631 16,466 ENE 2 6 30 80 205 18,499 109,046 11,809 8,419 11,956 E 2 6 30 80 105 18,040 342,003 42,808 10,255 53,990 ESE 2 6 30 80 105 34,158 170,123 23,960 39,354 15,115 SE O 495 30 80 7,240 45,405 9,298 105 7,591 6,259 SSE O 105 30 80 105 16,028 9,860 3,496 6,115 8,886 S 0 6 30 80 105 610 4,574 3,107 4,707 11,739 SSW 2 6 200 300 105 635 4,807 3,543 4,667 7,343 SW 4 6 2,000 1,800 105 1,846 5,798 2,390 6,345 16,152 WSW 2 6 150 300 105 402 7,318 7,095 19,774 184,704

'f W 2 6 30 80 105 728 2,074 71,132 28,610 65,312 WNW 2 6 30 80 105 561 2,547 14,966 5,636 9,794 NW 4 6 30 80 105 423 1,754 3,344 17,568 9,754 NNW 4 6 30 80 105 711 2,282 3.318 3,429 6,086 Annular totals 40 684 2,740 3,440 1,680 107,739 719,892 2'32,639 205,794 473,404 Grand total 1,748,052 i

2. 3 Land Use The Nuclear Sciences area, the focus of interest at the West Jefferson site, is adjacent to the site's northern boundary. It consists of a 10-acre fenced area enclosing a guardhouse, four buildings, and two other small structures on a flat bluff above Battelle Lake to the south and Big Darby Creek to the east.

The eastern edge of the bluff drops rather abruptly from an average elevation of 277 to 265 m (910 to 870 ft) MSL, then more gradually to the 262-m (860-ft)

MSL elevation of the Big Darby Creek floodplain. The land out to about 3 km (2 mi) to the north, west, and south is essentially cleared farmland, although there is one narrow wooded area along the northern portion of the fence around the Nuclear Sciences Facil.ity and another wooded area about 300 m (1000 ft) to the northeast. To the east, within the Big Darby Creek floodplain and along the bluffs to the east of the creek, the land is heavily vegetated with decidu-ous trees, scrub, and high grasses.

There are 18 industries located within 16-km (10-mi) radius. Of these, only four employ more than 100 people. These are White-Westinghouse Electric Corpo-ration, General Motors, Janitrol Aircraft, and Capital Manufacturing Company.

Each of these is located at least 13 km (8 mi) from the facility. Close to the site, within West Jefferson, are three small industries that individually em-ploy less than 60 people. The primary agricultural activity in the area is the raising of field crops such as corn and soybeans. About 10 percent of the land area in agricultural use is devoted to the pasturing of beef and dairy herds.

The short-term land commitments associated with the VRDF would be small (about 7500 sq. ft.) and would be limited to property already committed to radioactive

, materials processing.

2.4 Geology The arrangement .. geological strata in the BCL Facilities area consists of glacial till and outwash with formations of clay, sands, and gravel. The sands and gravel of the outwash are found in scattered, thin, discontinuous lenses within the till which is composed of unstratified clay containing fragments of rock. The unglaciated basement fonnations in the West Jefferson area, at depths of from about 80 to 100 feet, consist of nearly horizontal beds of lime-stone, dolomite and shale several hundreds of feet thick. Surface soils con-sist of patches and mixtures of: Brookston Silty Clay Loam, Crosby Silt Loam, Lewisburg Silt Loam, Celina Silt Loam and Miamian Silt Loam. The greatest por-

tion of the surface soils is represented by the Brookston-Crosby Association l with little more than traces representing the remaining types. All of these

! soil types exhibit relatively low permeability and all grade into till clay at l depths of 55 to 60 inches where the impermeability of the near-surface geology nearly precludes further percolation.

There have been no recorded earthquakes within 50 miles of the area of interest, i although in 1937 a strong quake was experienced at Anna, Ohio, a little over 50 miles to the northwest of the West Jefferson site. The Columbus-West Jeffer-son areas are, however, considered to be in an aseismic region.

l

[

2-5 l

, e d

i 2.5 Hydrology There are two aquifers, or sources of water, in the site area. The shallow aquifer is, of course, the dense clay till. The deep, or principal, acquifer is the limestone bedrock underlying the till. Earlier wells in the site area ranged in depth from 10 to 40 feet, which placed them in the glacial deposits.

Till is not very permeable and yields water slowly. The effective velocity of i

l water moving through clay under a hydraulic gradient of one percent is reported to be less than 0.004 foot per day; for water moving through silt, sand, and loess under the same gradient, the rate is about 0.0042 to 0.065 foot per day.

j Water movement in the till at the Battelle site is probably within the range of the former figure, since the hydraulic gradient of the water table in the area 2

3 is only slightly greater than one percent.

l The present wells at the Battelle facility lie below the surface of the bedrock.

i. The north well is 130 feet deep, the centrally located well in the Life

" Sciences area is 162 feet deep, and the south well is 138 feet deep. Bedrock was encountered at approximately 103 feet below the surface in drilling these wells.

! 2.5.1 Surface water i

A man-made hydrologic feature of the site is the artificial lake covering an ,

I area of about 25 acres that was formed by damming Silver Ditch south of, and down gradient from, the Nuclear Sciences area. The normal surface elevation 4

of the lake is 888 feet MSL.

The source of ground water in the site area is local precipitation. Recharge

, to the shallow aquifer takes place relatively uniformly over the area. Contours of the water table, which are about 40 feet below the surface, are a subdued 4

replica of the surface topography. Ground water moves downslope at right angles

,l to the contours and follows a path similar to surface runoff. At the Nuclear Sciences area surface runoff moves downslope into the lake, thence through the controlled dam on the site into Big Darby Creek. All ground water in the site i

area, and that entering on the site, is already near its place of discharge.

2.5.2 Surface Flooding Potential Flood hydrology calculation for the lake indicated a capacity of releasing water that was about three times the inflow rate measured during the January 1959

! floods. It can be concluded that the lake has not adversely affected the hy-

drology of the area.

l The ground floor level of the VROF is about 910 ft on the USGS mean sea level -

datum. The BCL West Jefferson site has been reviewed with respect to flooding.

The safety of the VROF'from flooding'by Big Darby Creek was demonstrated by ,

comparison with the probable-maximum flood (PMF), computed by the Corps of Engi-

! neers as 294,000 cfs for the downstream Big Darby Creek Dam with a drainage j area of 441 mi2 The capacity of the creek adjacent to the laboratory, deter-l mined from conservative parameters, is about 329,000 cfs at an elevation of l 900 ft MSL. .Thus, the channel capacity adjacent to the VROF at an elevation l

10 ft below grade is greater than the PMF for a drainage area of 441 mi2, 2-6

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i 2.6 Meteorology and Climatology Climatology of the. south-central Ohio region may be described as continental temperate. As.such, the region is subject to a wide seasonal range in tempera-

ture. Precipitation is distributed fairly uniformly during the year, although 60 percent falls during the spring and summer seasons. The annual monthly average rainfall is about 3.5 in. , and the greatest recorded rainfall for any 24-hour period was 3.87 in. in July 1947.

i No onsite wind / stability data are collected by Battelle at the site. However,

' the information collected by the National Weather Service at the Port Columbus International Airport is considered to be representative of wind / stability con-ditions at the site. Wind information from the National Weather Service's STAR program for the period 1970-1974, based on data every third hour, was used to e

derive a joint frequency distribution of wind direction by speed class. The most frequent wind direction is south (13.0 percent); winds in the sector from southeast to southwest occur 39 percent of the time. Stronger winds (greater lq than 21 kt) are mostly from the southwest to west-northwest, but occur only 0.7 percent of all hours. The average wind speed is 8.2 kt; calms occur

! 2.9 percent of the time.

1 4

i The average annual relative concentration (X/Q) and relative-deposition (D/Q) values for the site were calculated using five years (1970-1974) of National

!- Weather Service STAR data from the Port Columbus Internationa'l Airport and the X0QD0Q model developed by the NRC. Table 2-2 provides X/Q values at selected i

. distances for 16 directions from the West Jefferson site. The X/Q values in the table were calculated for continuous ground-level releases. The model in-4 cludes an allowance for plume meander during light winds and stable atmospheric

{ conditions; the open-terrain correction factor was not used.

The accident case (short-term, up to 2-h) relative concentrations have been i computed, using the Port Columbus meteorological data and the NRC' accident dis-j persion model, and are given in Table 2-3. The model is direction-dependent j

and calculates the X/Q values out to a distance of 5 km (3 mi) immediately fol-i lowing the release. The calculation computes the X/Q values that are exceeded l 50 percent of the time as a function of distance and direction. The model includes allowance for plume meander during light-wind and stable atmospheric conditions.

2. 7 Background Radiological Characteristics Based on aeroradioactivity measurements of the region including the BCL facili-ties it is estimated that the natural terrestrial background for area surround-ing BCL in 60 mrem / year. This number is equal to the average natural terrestrial -

background for the U.S. The cosmic background for the State of Ohio is averaged i

to be 50 mrem / year, compared to a U.S. average of 45 mrem / year. The estimate I for natural whole-body internal background is considered to be 25 mrem / year for the U.S. with only minor regional variations. Based on these figures, the total natural background near the BCL facilities is approximately 135 mrem / year, as compared with an average of 130 mrem / year for the United States as a whole.  !

l 2-7 l

4

= 4 Table 2.2 Annual Average Relative Concentrations for the BCL Sitett (s/m3)

Distance (km)

Sector 0.8 1.6 3.2 6.4 16 40 80 N 5.1-6t2 1.6-6 5.2-7 1.9-7 5.1-8 1.5-8 5.8-9 NNE 1.8-6 5.4-7 1.8-7 6.2-8 1.6-8 4.6-9 1.8-9 NE 1.6-6 4.9-7 1.6-7 5.7-8 1.5-8 4.2-9 1.7-9 t

ENE 1.2-6 3.7-7 1.2-7 4.3-8 1.1-8 3.2-9 1.2-9 E 2.1-6 6.5-7 2.1-7 7.5-8 2.0-8 5.6-9 2.2-9

, ESE 1.4-6 4.4-7 1.5-7 5.2-8 1.4-8 4.0-9 1.6-9

SE 1.8-6 5.7-7 1.9-7 6.8-8 1.9-8 5.3-9 2.1-9 SSE 2.4-6 7.5-7 2.5-7 9.1-8 2.5-8 7.3-9 2.9-9 S 6.5-6 2.0-6 6.8-7 2.5-7 6.8-8 2.0-8 8.1-9

SSW 4.3-6 1.3-6 4.5-7 1.7-7 4.7-8 1.4-8 5.6-9 4.8-6 SW 1.5-6 5.0-7 1.8-7 5.1-8 1.5-8 6.1-9 WSW 3.2-6 1.0-6 3.4-7 1.2-7 3.5-8 1.0-8 4.1-9 W 7.4-6 2.3-6 7.8-7 2.8-7 8.0-8 2.4-8 9.7-9 WNW 4.4-6 1.4-6 4.6-7 1.7-7 4.7-8 1.4-8 5.6-9 NW 3.9-6 1.2-6 4.0-7 1.4-7 4.0-8 1.1-8 4.6-9 i NNW 3.4-6 1.0-6 3.5-7 -

1.3-7 3.5-8 1.0-8 4.2-9 1

t Based on continuous ground-level release and five years of meteorological data from Port Columbus International Airport, Columbus, Ohio.

t2 Scientific notation: 5.1-6 = 5.1 x 10 8 3

2.8 Ecology 2.8.1 Terrestrial Ecology Wildlife habitat within an 8-km (5-mi) radius of the West Jefferson Nuclear Sciences facility is rather sparse, as a result of farming practices, and is

' principally limited to fencerows, woodlots, and a wooded area along the Big Darby and Little Darby Creeks.

2.8.2 Aquatic Ecology L

Currently, Big Darby Creek has one of the most unique and diverse benthic and fish communities in Ohio, and is being considered by Ohio Department of Natural Resources for possible designation as a scenic river. The stream is populated -

by a large number of fish, insect larvae, and mollusks that are indicators of good water quality. Some of these organisms are larvae and nymphs of mayflies, lamselflies, stoneflies, freshwater naiads, various darters and shiners, crappie, bass, and sunfish.

[ .

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J Table 2.3 Fifty Percentile Short-Term (2-h) Relative Concentrations for the BCL Sitet(s/m3)

Distance (km)

Sector 0.15 0.5 1 2 5 N 8.0-4t2 1.3-4 4.3-5 1.5-5 3.3-6 NNE 5.9-4 9.9-5 3.0-5 9.2-6 2.3-6 NE 5.3-4 7.8-5 2.4-5 8.4-6 2.1-6 ENE 5.4-4 8.0-5 2.6-5 8.9-6 2.3-6 E 5.8-4 9.9-5 2.6-5 1.0-5 2.8-6 ESE 6.4-4 9.3-5 3.1-5 1.1-5 3.0-6 SE 6.9-4 1.0-4 3.4-5 1.2-5 3.5-6 SSE 9.7-4 1.4-4 4.8-5 1.7-5 4.8-6 S 1.2-3 1.7-4 6.1-5 2.3-5 6.9-6 SSW 1.5-3 1.4-4 5.1- 5 2.8-5 9.0-6 SW 1.4-3 1.4-4 5.1-5 2.2-5 8.2-6 WSW 1.3-3 1.8-4 6.3-5 2.5-5 7.8-6 W 1.3-3 1.4-4 5.1-5 2.2-5 7.2-6 WNW 1.0-3 1.9-4 6.6-5 2.5-5 7.7-6 NW -

1.1-3 1.6-4 5.4-5 2.0-5 5.4-6 NNW 8.0-4 1.7-4 4.3-5 2.1-5 6.3-6 t 1Based on five years of meteorological data from Port Columbus International Airport, Columbus Ohio.

t 2Scientific notation: 8.0-4 = 8.0 x 10 4 2.9 References

1. Environmental Impact Assessment, Battelle Memorial Institute Laboratory, Columbus, Ohio, Report No. SAI 81-307-WA, prepared for U.S. Nuclear Regulatory Commission; February 2,1981.

2. NUREG-0893, The Effects of Natural Phenomena on the Battelle Memorial Institute Building JN-18 Facilities at West Jefferson, Ohio, March 1982.

3. Report on Safety Related Information for the Battelle Volume Reduction Demonstration Facility by Battelle Columbus Laboratories, Columbus, Ohio and ATCOR Engineered Systems, Inc., Avon, Connecticut; August 15, 1983. -

(Appendix G to Renewal Application BCL-1081) 2-9

3.0 THE FACILITY 3.1 External Appearance The proposed facility external structure is comprised of two major adjacent areas: the process building and the waste storage building. The facility structure will be designed and constructed in accordance with the State of Ohio Building Codes. The process building is a multi-story structure 45 ft x 60 ft x 52 ft high with a stack that discharges at'a point about 132 ft above ground.

The waste storage building is a single story structure, 60 ft x 80 ft with a loading dock for truck loading / unloading of waste. The facility is constructed on a 6 in.' thick, reinforced concrete slab. Exterior walls are insulated, corrugated steel siding.- The roof is galvanized steel decking covered with a vapor barrier, rigid insulation, and built-up roofing material.

3.2 Summary of Operations / Processes The proposed VROF would consist of facilities to receive and store LLW from nuclear power plants, medical institutions, and industrial users of radioactive materials under terms of negotiated contracts, an incinerator to treat combus-tible wastes, all necessary auxiliary equipment and services, and facilities to store the volume-reduced wastes prior to shipment back to the generators or to licensed disposal LLW facilities.

This section will describe the facility operations and processes. Enough detail will be given to provide a general understanding of the VROF operation,-then other descriptive documents will be referenced that would provide more detail.

Figure 3.1 is a plan view of the VRDF showing the relative location of the prin-cipal components making up the facility.

3.2.1 Receipt of LLW All LLW would be shipped to the VRDF by highway. The trucks containing waste materials would be received at the truck loading and unloading dock, which is a part of the waste storage building. Unloading would take place at that dock.

Containers of waste would be moved by forklift or drum carts to the drum storage area or the liquid waste storage area.1 For more detailed information on the procedures associated with receiving waste see Reference 1 (Section 3.3.1).

3.2.2 Preprocess Staging and Storage .

The drum storage and liquid waste storage areas constitute staging areas for the accumulation of quantities of incoming material sufficient to permit effi-cient processing of a material generator's batch in the incinerator. The storage areas have a capacity of about 550 incoming waste drums. Containers are moved from storage to'the ground floor of the incine*ator building, via ' forklift or drum carts, where they are loaded onto the freight elevator. They are off-loaded on the top floor using a drum cart or a motorized lift dolly. For more informa-tion see Reference 1 (Section 3.3.1).

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3.2.3 Incineration The proposed incineration process is as developed and manufactured by Kraftanlagen AG Heidelberg and represented by ATCOR Engineered Systems, Inc.

The process as developed by Kraftanlagen and as represented by ATCOR is described in a topical report.2 The process consists of a controlled-air incin-erator (Section 3.2.3.1), a process gas cleanup system (Section 3.2.3.2), and an ash handling system (Section 3.2.3.3). Figure 3.2 is a schematic drawing of the incinerator process.

The incinerator would be capable of converting combustible LLW (such as rags, paper, plastics, rubber, and wood), scintillation liquid, biological material, and contaminated oil into an ash that would be packaged for disposal.

3.2.3.1 Incinerator The Kraftanlagen controlled-air incinerator is a two-stage combustion incinerator.

The primary combustion chamber would operate at a maximum temperature of about 1450 F to ignite the waste. The combustion air to the primary chamber would be restricted, resulting in pyrolysis. The gaseous combustion products would pass to the secondary chamber, which would be maintained very air rich at a temperature of about 1650'F, for the purpose of completing the oxidation of the gaseous combustion products. The char that is formed in the primary chamber is also passed through to the secondary chamber where combustion is completed. The gaseous combustion products are moved by induced draft fans through a process gas cleanup system.

In October 1985, a NRC staff member' visited the Kraf tanlagen AG offices in Heidelberg, Wect. Germany. During the visit the ARAK incinerator facility at Karlstein was observed. This system is a scaled up version of the Juelich prototypea and is essentially the system proposed for installation at BCL. The ARAK system differs from its predecessors by the substitution of bag filters for steel mesh filter drums. The ARAK incinerator was nearing completion and was being readied for the initial heating to set the masonry and temper the ceramics. The NRC staff member felt that it was a very good design and very well constructed.

More information on the incinerator system and operations can be found in the safety report 1 (Section 3), the topical reports 2,3, and the applicant's environmental assessment.4 3.2.3.2 Process Gas Cleanup System Process gas exits the secondary combustion chamber at about 1650*F, leaving about 70 percent of its ash loading behind in the ash cooling chamber, and enters the hot gas filter. The hot gas filter removes about 97 percent of the particulate in the gas stream. The process gas is then mixed with ambient air that reduces the composite gas temperature to less than 500*F before it enters a series of mesh filters. The mesh filters, which are bag filters, remove 70 percent of the particulate presented to them. Final filtration is achieved through HEPA filters that are designed to be 99.95 percent efficient against 0.3 micron particles. The cleanup efficiency of this series of filters, ex-pressed as a decontamination factor, is less than 1.35 x 10 8 That is, the 3-3

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l particulate mass' leaving the system is less than 1.35 x 10 8 times the parti-culate (ash) leaving the secondary combustion chamber. More information on the

process gas cleanup system may be found in Reference 1 (Section 3.0).

3.2.3.3 Ash-Handling System

'l Ash from the incineration process is accumulated at three locations: the incinerator ash cooling chamber, the hot gas filter ash cooling chamber, and

, the mesh filter ash discharge lock. Empty drums are brought from the empty drum storage area to those locations, which are on the ground floor of the incinerator building. The drums are attached to a lock, the hopper discharge valves operated, and the drums filled to about 90 percent of. capacity. The drums are then sealed, surveyed, weighed, and removed to the caged drum ash i storage area in the waste storage building. More information on ash recovery

and storage may be found in Reference 1 (Sections 3.1.3 and'3.3.2).

l 3.2.3.4 Shipment of LLW Ash The ash storage area has a capacity of about two truckloads and will accommo-date about four months production. Ash shipments will be scheduled when a truckload quantity of ash has been accumulated - about once every two months.

The ash drums will be removed from storage and loaded onto a truck trailer i' using a forklift, barrel cart, or other suitable handling equipment. The ash produced will meet the requirements of LLW to be disposed of by shallow land burial.

l, j 3.3 Transportation to and from the Facility

~

i l All LLW would be shipped to the VROF by highway. This section describes j possible routes and shipping methods.

]:

3.3.1 Routes i Waste materials from material generators would be transported to the VROF on a j combination of State and Federal highways. LLW can be shipped on any of the j

roads in Ohio. The routing generally is determined by the carrier. In any event incoming and outgoing shipments will enter and leave the site on the one-i mile stretch of the Georgesville - Plain City Road (State Route 142) that l connects the site with I-70. Interstate Highway 70 would be used as the artery 1

I for shipments to and from the BCL facility.

3.3.2 Shipping Methods

Trucks typically would have closed trailers, but flat-bed trailers would be i used for large containers.

i j 3.4 References '

1 1. Report on Safety Related Information for the Battelle Volume Reduction l Demonstration Facility by Battelle Columbus Laboratories, Columbus, Ohio i and ATCOR Engineered Systems, Inc., Avon, Connecticut; August 15, 1983.

j (Appendix G to Renewal Application 8CL-1081)

, 3-5

s

2. ATCOR/Kraftenlagen Controlled Air Pyrolysis Incinerator, Kenneth H. Dufrane and Manfred Wilke, Presented at ANS Topical Meeting on Treatment and Hand-ling of Radioactive Waste, April 1982, Hanford, Washington.

3. Incineration of Radioactive Wastes Applying the "Juelich Incineration Process," Manfred Wilke and Klaus Fatho, Heidelberg, April 1981.

4. Environmental Impact Assessment, Battelle Memorial Institute Laboratory, Columbus, Ohio, Report No. SAI 81-307-WA, Prepared for U.S. Nuclear Regula-tory Commission; February 2,1981.

l i

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I i

4.0 CHARACTERIZATION OF INCOMING WASTE AND VRDF END-PRODUCT Section 4.1 discusses the characterization of the VRDF incoming waste. Sec-tion 4.2 discusses the form of the VRDF end product that would be either re-turned to generators or disposed in a licensed LLW disposal site. Section 4.3 lists the references used.

4.1 Characterization of Incoming Waste The VRDF would process LLW resulting from the operation of nuclear power plants, industrial, and institutional facilities. Wastes containing transuranic ele-ments will be processed only if their concentration is less than 10 nCi/gm.

Section 4.1.2 describes the volumes of waste that were used in the environmental analyses. Section 4.1.3 describes the isotopic composition of the waste that would be expected to be processed at the VRDF.

Processing of LLW would be accomplished by incineration. In order to incinerate LLW, the requirements of 10 CFR 20 must be met. 10 CFR 20.305 places restric-tions on the treatment or disposal of waste by incineration by requiring com-pliance with 10 CFR 20.106. 10 CFR 20.106 sets limits on the concentrations of radioactive material in air and water to be released to unrestricted areas. The maximum permissible concentration (MPC's) are listed in Appendix B, Table II of 10 CFR 20. Incineration of the expected LLW at the VRDF would resbit in air-borne releases in concentrations very low in comparison with the MPC's listed in this appendix of 10 CFR 20, as shown in Table 6.9 of this document. (There would be no liquid effluents from the operation of the incinerator.)

In order to ensure that effluents resulting from the operation of the VROF stay within 10 CFR 23 limits, BCL would set contractual limits on the types and quantities of isotopes that would be accepted for processing. Only Class A waste as defined in 10 CFR 61 will be received or processed. The generators would describe the contents of the waste containers in the shipping manifests.

It should be noted that the generators and shippers are NRC-licensed and there-fore must meet NRC requirements for identifying the quantity and type of radio-l active material shipped. Verification of generator's data and the shipment inspection and surveys will be made by a method and at a time designated by established Battelle Accountability and Quality Assurance Operational Procedures.

Portable survey meters used to measure the packages' external radiation levels i

would not detect low-energy beta emitters, such as carbon-14 and tritium in

! received waste. Since these isotopes would not be efficiently trapped by the off gas treatment system of VRDF building ventilation system, their levels in l effluents would be subject to uncertainty. To reduce this uncertainty to a minimum the incinerator exhaust gas stream will be continually monitored for l oeta gamma activity. In addition the gas stream will be continuously sampled and periodically analyzed for both tritium and carbon-14.

i l

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. =

4.1.1 Waste Generators and Characteristics 4.1.1.1 Nuclear Power Plants The VRDF would accept combustible wastes containing some uncombustible solids and contaminated waste oil from nuclear power plants. The combustible waste would consist of items such as paper, wood, cloth, plastics, rubber, resins, oils, and scintillation liquids.

4.1.1.2 Institutional Facilities Institutional waste generators include colleges and universities, medical schools, research facilities, and hospitals. These institutions use radioactive materials in many diverse applications. Radio-labelled pharmaceuticals and biochemicals are used in nuclear medicine for therapy and diagnosis, and in biological research to study the physiology cf humans, animals, and plants.

Radioactive materials are also used in many other academic disciplines such as chemistry, physics, and engineering.

Institutional wastes may be classified into four significant groups: Liquid scintillation vials containing scintillation fluid (shipped with absorbent materials); other liquids (solidified or shipped with absorbent materials);

biological wastes (shipped with absorbent materials and lime); and trash.

Liquid scintillation vials are made of glass and occasionally polyethylene, and are usually about half full of counting fluid. The majority of scintilla-tion fluids are flammable organic solvents (e.g. , toluene, benzene, xylene).

Liquid scintillation counters are normally used to detect beta emitting radio-nuclides and less frequently to detect alpha-emitting radionuclides. Liquid scintillation fluids have low concentrations of carbon-14, iodine-125, and tritium. The remaining liquids are aqueous and organic solvents generated by analytical procedures such as tracer studies. Biological wastes are generated primarily through research programs at universities and at medical schools.

The waste consists of ' animal carcasses, tissues, animal bedding and excreta, as well as vegetation and culture media. Institutional trash consists almost entirely of materials such as paper, rubber or plastic gloves, disposable and broken labware, and disposable syringes.

4.1.1. 3 Industrial Facilities Industrial LLW streams are expected to consist of the same four waste groups as institutional LLW streams; liquid scintillation vials, absorbed liquids, biological wastes, and trash. The major contributors are pharmace'utical companies, independent testing laboratories, and analytical laboratories.

4.1.1. 4 Hazards Much of the untreated waste generated by nuclear power plants, industrial, and institutional facilities contain many chemicals. In most cases, the chemicals are present in low concentrations and are confined to a few waste packages representing a small fraction of the total waste volume. The waste streams listed below, however, contain significant quantities of chemicals.

Liquid scintillation vials contain toluene, benzene, xylene, which may contain l 5-10 gram / liter of scintillators. These aromatic solvents are also very 4-2 1

O %

flammable. For example, solutions with a base solvent of xylene have flash points ranging 58*F to 97 F, and those with a base solvent of toluene have flash points ranging from 40 F to 47 F.

Absorbed liquids may contain aqueous solutions of salts and chelates and a variety of toxic organic solvents and compounds, and biological wastes may contain traces of radio-labelled compounds.

The incineration process would provide complete oxidation of the above chemi-cals. Resultant emissions would be expected to be carbon-dioxide and water.

Because of the possibility of formation of dioxins in municipal incinerators, emission of dioxins from the VROF incinerator was examined. Appendix C of this report provides detailed information about the formation of dioxins, and concludes that dioxin would not be released from the VRDF incinerator.

4.1.2 Waste Volumes 4.1.2.1 Incoming Waste Volumes Used .in Environmental Assessment BCL assumes that the incinerator will operate a maximum of 7200 hours0.0833 days <br />2 hours <br />0.0119 weeks <br />0.00274 months <br /> per year, which is equivalent to operating 300 24-hour days per year.1 This is done at a feed rate of 330 pounds of waste per hour. On the basis of 330 lb of waste charged per hour during 7200 hours0.0833 days <br />2 hours <br />0.0119 weeks <br />0.00274 months <br /> of operation per year, LLW will be received at an average rate of one shipment every other day consisting of about 6.5 tons of waste per shipment.

At this rate the incoming waste, at 8.95 pounds per cubic foot averages about 265,000 cubic feet per year. It is assumed that this quantity is equally divided between reactor waste and industrial / institutional waste.

4.1.2.2 Reactor Waste 4 The projected isotopic concentrations in reactor waste are shown in Table 4.1.

i All of the isotopic concentrations except tritium and carbon-14, were calculated using information provided in the AECC Topical Reportz that has been accepted for referencing in nuclear power plant license applications by the NRC.3 The isotopic concentrations of waste from pressurized water reactors (PWR's) were used because they were slightly higher than those for boiling water reactors (BWR's).

The isotopic distribution for PWR's is listed in Table XV of the AECC Topical l Report. In order to calculate the concentration of each isotope, the number i of curies per year per plant was divided by the expected volume of waste per year per plant. The expected volume of waste generated per plant is given in l Table IV of the AECC Topical Report and is estimated to be 7600 cubic feet per year. This is the non-compacted waste volume, but, since most of the waste shipped from nuclear power plants is compacted prior to shipping, a volume reduction factor of 3:1 was included in the calculations. The calculations used to generate the isotopic concentrations shown in Table 4.1 may be found in Appendix B, Calculation 6.

The isotopic concentration for tritium and carbon-14 were obtained from the PWR compactible and combustible waste description given in the Data Base for l

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Radicactive Waste Management: Waste Source Options Report.4 This report is described in the following section. 1 Table 4.1 Projected Isotopic Concentrations in Reactor Waste Isotopic Concentration Isotope (mci /ft3)

Cr-51 2.9E-02*

Mn-54 6.4E-02 Co-58 6.0E-01 Co-60 7.9E-01 Sr-90 9.9E-04 Zr-95 9.9E-03 Ru-106 7.9E-03 Sb-125 1.9E-03 Cs-134 1.2E-01 Cs-137 3.1E-01 H-3 2.6E-02 C-14 9.5E-04 I-125 0.00+00

• In this and following sections, "E" denotes exponent. For example, "2.9E-02" means 2.9 x 10-2, or .029.

4.1.2.3 Industrial and Institutional Waste Most of the information given in this section was taken from the Data Base for Radioactive Waste Management: Waste Source Options Report.4 In this' report, LLW was separated into 37 waste streams. Each waste stream was characterized in terms of its volume, physical, chemical, and radiological properties as

, projected to be routinely generated during the years 1980 through 2000. The l most important radionuclides present in each waste stream were identified and

! the geometric mean of the range of activity concentrations for each radio-nuclide was determined from available data.

i

! The expected isotopic composition of industrial and institutional waste is l shown in Table 4.2. The isotopic concentrations (except for iodine-125) were

taken directly from the above report for the compactible and combustible t

institutional / industrial waste stream.

The isotopic concentration of iodine-125 was calculated from information given in a Pennsylvania study summarizing a comprehensive survey of its LLW genera-tors.5 Many documents characterizing LLW were reviewed, and most of them did l not include iodine-125 since it is a relatively short-lived isotope. The l Pennsylvania study was one of the few documents found to include iodine-125, and it was the most detailed. The concentrations of iodine-125 in Pennsylvania's LLW is not necessarily that of the waste that would be processed at the VRDF, nor is it possible to accurately predict which generators would use the VRDF,

, since it is not yet in operation. However, it was judged by the staff to be l

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e o Table 4.2 Projected Isotopic Concentrations in Industrial and Institutional Waste Isotopic Concentration Isotope (mci /ft3)

Co-60 2.9E-01 Sr-90 4.1E-02 Tc-99 9.6E-08 Cs-137 1.3E-01 Am-241 1.4E-04 H-3 2.6E+00 C-14 1. 5E-01 I-125 1.6E-01 representative of the iodine-125 concentration to be generally found in the industrial / institutional wastes that would be processed in the VRDF.

The isotopic concentration shown in Table 4.2 for iodine-125 was calculated by.

dividing the total iodine-125 activity given for academic, industrial and medical wastes by the total volume of LLW that was shipped to commercial disposal sites i or brokers from Pennsylvania generators. '

4.2 Characterization of VROF End-Product .

The VROF end product would be non-combustible solids incinerator' ash. The end-product would be shipped from the VROF back to the generator or to a licensed LLW disposal site. Assuming a mass reduction of 8:1, ash would be shipped out at an average rate of one truckload, containing about 12 tons of ash, per month.

The VROF end product would meet the applicable regulations in 10 CFR 61 that define the requirements for land disposal of radioactive waste. The VRDF end-product would be Class A waste, as defined in 10 CFR 61.55. The VROF end product

would also meet the requirements set in 10 CFR 61.56. These requirements include l

limitations on packaging, free liquids, explosives, toxic gases, chemical com-position, pyrophorics, biological and pathological waste. They also include requirements that the waste package must be structurally stable.

'The end product container would be labeled according 10 CFR 61.57 which requires that the waste package be clearly labeled to identify whether it is Class A, B, ,

or C waste. As stated above, the VROF end product is expected to be Class A l-waste.

4.3 References

1. Report on Safety Related Information for the Battelle Volume Reduction Demonstration Facility by Battelle Columbus Laboratories, Columbus, Ohio and ATCOR Engineered Systems, Inc., Avon, Connecticut, August 15, 1983.

i (Appendix G to Renewal Application BCL-1081)

2. Topical Report, Mobile Volume Reduction System, Topical Report No. AECC-4-NP-A, Revision 1, January 15, 1986.

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3. NRC letter, C. O. Thomas to R. Garcia (AECC), subject " Acceptance for Referencing of Licensing Topical Report AECC-4(P/NP), Mobile Volume Reduction System," October 26, 1984.

4. R. E. Wild, et al. , Data Base for Radioactive Waste Management: Waste Source Options Report, Dames and Moore, NUREG/CR-1759-V2, November 1981.

5. T. E. Pollog, Pennsylvania Low-Level Radioactive Waste Management Survey, November 1984.

e 9

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1 5.0 WASTE CONFINEMENT AND EFFLUENT CONTROL 5.1 Waste Confinement Sections 5.1.1 through 5.1.6 discuss the waste confinement methods that would be used during VRDF operations. " Waste confinement" refers to the physical limits and administrative procedures used to keep radioactive waste within i specified bounds. In the VRDF, waste confinement would be achieved using a combination of administrative procedures, the waste containers themselves, the process equipment, and the physical barriers of the VRDF building.

5.1.1 Receipt of LLW Material All LLW would be shipped to the VRDF by truck. During shipping, the first level of confinement would be provided by the waste containers themselves. These containers would meet the applicable Department of Transportation (DOT) regula-tions. The second level of confinement would be provided by the shipping trailer's walls and roof; except when large waste containers were shipped, in which case open flatbed trailers would be used. The open flatbed trailers would not provide a second level of confinement.

Before off-loading, the truck would be checked for external radiation as required by 10 CFR 20. If contaminated, the truck would be decontaminated before further processing wo~uld occur. If found to be free of contamination, the truck would be opened and checked for loose surface contamination. Also, as the packages were removed, they would be checked for loose surface contamination and contact radiation level.1 5.1. 2 Proproqpss Staging and Storage The waste containers would ' continue to provide the primary level of confinement during the various staging and storage operations. The VRDF, with insulated corrugated steel siding and galvanized steel roof decking, would provide a secondary level of confinement. The building would operate at a negative pressure (with respect to ambient conditions) to control potential airborne contamination. Air from the waste storage building is not filtered before it

! is exhausted through vents to the atmosphere. (See Section 5.2.1.5.)

I 5.1. 3 Waste Loading ,

Waste drums will be removed from the drum storage area and moved to the top floor of the process building by means of a freight elevator. The drums of

waste will be moved to the charging area of the incinerator with a drum cart i or motorized lift dolly. Each drum is lifted and fitted to the incinerator charging lock with a lifting device which is part of the incinerator. The chamber is an air-tight steel box subdivided by a pneumatic slide gate. It is i

maintained at subatmospheric pressure by filtered exhaust ventilation. Once

! within the charging lock, the drum head is removed in such a way that the exterior of the drum and the drum head are not exposed to the waste charging chamber. After the waste has been removed from the drum and the head replaced, l

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, y 1 the empty drum will be removed from the charging lock. The head will be resealed to the drum opening. Before mcving the drum from the charging area, the external surfaces will be cleaned as necessary, especially near the drum opening. The drum will be surveyed and smeared before being temporarily stored in the charging room. After the smears have been counted and it has been assured that the surfaces are clean, the empty drums will be moved to the ground floor and returned to the storage building. They will be used for either ash disposal after recertification, returned to the waste generator from whom they came, or disposed of as waste.

Waste handling in this manner assures that the waste package contents are separated from the environment by at least two levels of confinement. The process building operating floors are ventilated and the exhaust gas is passed through HEPA filters before being vented to the outside atmosphere. These measures assure a high degree of particulate confinement.

5.1. 4 Incinerator Operation The incinerator operation is completely housed in the process building. The process, for which a dotailed description is provided in the license applica-tion,1 consists of waste combustion, off gas treatment, and ash handling. The off gas treatment, operating area and exhaust ventilation systems are designed to confine radioactive particulate to the process equipment and HEPA filter systems and to produce Al. ARA conditions for airborne radioactive materials in operating areas of the facility.

5.1.4.1 Incineration .

Once the waste has been loaded into the drummed waste compartment, which is connected to the incinerator by a waste feed lock, the incinerator operation is started. The waste feed lock is an airtight steel duct with airtight pneumatic slide gates at the top and bottom. The inlet slide gate assembly is flanged to the bottom of the drummed waste compartment and the discharge gate is flanged to the incinerator pyrolysis chamber. The waste feed lock serves to separate the waste loading function from the atmosphere of the incinerator. To assure incin-i erator isolation from the loading chamber, interlocks prevent opening both waste l feed lock gates at the same time. Similar interlocks are installed at all locations where openings are used to feed or remove materials. When waste addi-tion to the incinerator is needed, the outlet gate is closed and the feed lock I

inlet slide gate is opened to receive material for the loading chamber. The inlet gate is closed when the feed lock is full, and the outlet gate is opened to admit the waste to the incinerator (pyrolysis chamber).

l The incinerator is a ste'el jacketed, airtight square column. It is flanged at i

' the top to the waste feed lock id at the bottom to the ash discharge hopper.

The incinerator, which has a multi-layer refractory lining and insulation, is divided vertically into a pyrolysis chamber and a combustion chamber by the l pyrolysis grates. Pyrolysis air is admitted through channels in the side wall i of the incinerator. Depending on the type of waste material, it can take 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to pass through the pyrolysis chamber; 1-1/2 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is typical for i most wastes. In any case both chambers are maintained at subatmospheric pressure by induced draft ventilation. Actuating shafts for grates and valves penetrate l the walls of the incinerator system and are not provided with leak-tight seals.

l The operators and actuators are enclosed in containments on the exterior of the

( system to provide confinement.

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l As outlined above, waste confinement is maintained by at least two levels of containment, multiple barriers such as airlocks and seals, and HEPA-filtered exhaust ventilation.

5.1.4.2 Off-Gas Treatment The off gas treatment system consists of a filtration train composed of hot gas filters, mixing chamber, mesh filters, and final filters. An airtight, steel flue gas discharge duct, which is refractory lined and insulated (2-1/2 feet inside diameter with 1 foot thick refractory), connects the combustion chamber to the hot gas filter, which is an airtight steel jacketed box with a multi-layer refractory lining. The hot gas filter has a 1.inged, steel, insulated cover that provides access to the filters for maintenance. The top of the hot gas filter is enclosed in a service room that has controlled, filtered ventila-tion to prevent contamination release during the hot gas filter change opera-tion. An ash discharge hopper is flanged to the bottom of the hot gas filter inlet plenum. This discharger hopper is similar to the incinerator ash discharge hopper.

i The filtered flue gas exits the hot gas filter through a refractory lined duct.

The flow is split to divert up to 20 percent of the hot gas back to the pyrolysis

, unit by way of a quench cooler. The remainder of the air is sent to the final

, cleanup system and stack. discharge.

A duct is available to allow the flue gas to bypass the hot gas filter in emer-gencies such as rapid plugging of the filter elements. This duct is 2 feet in diameter and is refractory insulated. The bypass is normally sealed by a specially designed cone valve. In an emergency the incinerator is shut down and i the bypass duct valve is op.ened manually. This allows flue gas to enter the downstream components of the incinerator system where other filters are present to remove particulates.

l The mixing chamber is a cylindrical steel housing fitted inside with baffles and swirl vanes welded to the interior of the housing. It is flanged to the refractory lined steel ducting from the hot gas filter and the insulated steel ducting leading to the mesh filter. A cooling air injection connection is located in l the mixing chamber refractory lined inlet plenum. Cooling air is supplied by i

the draft action of the induced draft fans.

I The mesh filters are airtight steel housings with arrays of mesh bags located inside. The mesh filter housings are flanged to the split flue gas ducting from the mixing chamber and to the ducting leading to the final filters. The flue, gas enters at the bottom of the filter units, flows through the bags (out-side to inside), and exits from the upper plenum. When filter efficiency can no longer be maintained by impulse cleaning of the bags, the bags are changed during incinerator downtime. The top of the unit has an access cover similar to that of the hot gas filter. Used filter bags are dropped into the bottom of l the units and removed through an ash discharge lock that is similar to that employed in the incinerator and the hot gas filter. The ash discharge lock also retains the ash that is dislodged from the mesh filter by impulse cleaning during normal operation.

The final filter units are housed in airtight steel boxes. They consist of two parallel stages of high efficiency air particulate filter units each with a bank of prefilter elements preceding the bank of HEPA elements (see figure 3.2).

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i The filter housings are flanged to the ducting from the mesh filter and to the ducting leading to the flue gas fan. Doors are provided for access to change out the filter elements. Filter elements are replaced by the bag-out method and can be loaded directly into the incinerator for disposal without pretreatment such as crushing or shredding.

All components of the off gas treatment system are housed in airtight chambers and attached by flanged ducts. They are operated at subatmospheric pressure and

' contained in ventilated rooms whose exhaust is filtered. Thus, at least two levels of confinement are maintained by the physical barriers that contain the off gas treatment system.

5.1.4.3 Ash Handling Ash hoppers are located at the incinerator, the hot gas filter, and the mesh filter.

The ash discharge hopper is flanged to the bottom of the combustion chamber.

It consists of two airtight steel boxes flanged together--the ash cooling chamber (top) and the ash discharge lock (bottom) with associated auxiliary support equipment.

A set,of ash grates is located at the top of the ash cooling chamber. Solid combustion products and noncombustibles accumulate on the ash grates, and are dumped automatically. The ash is cooled by water flowing between the walls of the double jacketed ash chamber. It is emptied periodically into the ash dis-charge lock.

The ash discharge lock has pneumatic slide gate valves at top and bottom. The upper slide gate is flanged to the ash cooling chamber. The discharge at the bottom of the lock is sealed with a slide valve and is provided with a container (drum) coupling device. The container coupling device seals the ash container to the ash discharge lock. The ash discharge lock is provided with controlled ventilation through local vents to the exhaust system to eliminate release of radioactivity during container filling and disconnect operations. To transfer the accumulated ash, the lower slide valve is opened to empty the lock contents, and the valve is closed again. The atmosphere in the region below the valve is purged through local vents to the exhaust system to remove radioactive, airborne particulates, and a negative pressure is reestablished before the drum seal is released. After the filled drum has been removed and covered, another drum is immediately coupled to the discharge leg.

In the case of the hot gas filter the ash hopper is separated from the hot gas filter by air cooled, ceramic insulated ash grates. The ash falls on the grates by separation from the flowing gas as the gas velocity and direction are changed and by spontaneous spalling of ash cake from the filter surfaces. The ash dis-charge lock has pneumatic slide gates at its top and bottom. A container cou-pling device is flanged to the bottom slide gate. The discharge lock promotes cooling of the ash. When the necessary volume of ash has accumulated in the lock it is discharged to a drum. The drum coupler and air exhaust system for contamination control are the same as for the incinerator ash discharge described above. A drum of ash is filled about once a day. The ash discharge lock is provided with glove ports, service windows, lighting installations, and ven-tilation. During operations, the windows and glove ports are protected by an insulated steel slide shield.

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An ash discharge lock is flanged to the bottom of each mesh filter. The ash discharge lock is equipped at the top with an insulated steel pneumatic slide gate for isolation from the mesh filter. At the bottom of the lock is another pneumatic steel slide gate which is flanged to a container coupling device for contamination-free discharge of ash to a waste container; the container coupling device and exhaust air controls are similar to the incinerator and hot gas filter ash discharge systems.

The primary level of waste confinement in the incinerator ash handling systems is provided by the discharge locks, air exhaust systems and/or the disposal con-tainers. The secondary level of confinement is provided by the VRDF building shell.

5.1.5 Post-Process Staging The procedure for loading the ash drums will be to move the empty drums as required from storage to the ash loading stations at the base of the several process units in the incinerator building. The heads will be removed and the drums fitted to the hoppers. The hopper discharge valves will be operated and the drums filled to about 90 percent of their volume. After standing for a reasonable time to allow the lighter ash particulates to settle, and after being purged with air to remove micro particulates, the drum will be removed from the ash hopper and the head attached.

The drum will be smeared, and as soon as it is ascertained that the exterior surfaces are clean, it will be removed from the incinerator ash loading area to the storage building. The drum will be weighed and all data, including the results of the survey and smear analyses, will be logged. The drum will then be removed to the ash storage area in the storage building. When the ash drums are removed from the storage area for loading on a truck trailer for shipment, each drum will be checked for proper identification against the record log.

Each drum will again be surveyed for surface dose rate and the surfaces smeared.

Drums will be loaded on the truck trailer using a forklift, barrel cart, or other suitable handling equipment. During this staging operation, the primary level of waste confinement is provided by the disposal containers. The secondary level of confinement would be provided by the VRDF building.

5.1.6 Administrative Controls 5.1.6.1 VRDF Area Controls The VROF would be divided into restricted areas and unrestricted areas as defined by BCL. The restricted areas would be comprised of the incinerator room, the waste loading area, and the ash handling areas. Radiation areas would be posted with radiation warning signs, as described in 10 CFR 20.203.

Only assigned personnel necessary for operation and maintenance are admitted to operating and control areas on a regular basis. Routine entrance and exit is through a single control area. Change rooms are provided for entrance to the potentially contaminated operating areas around the incinerator. All personnel entering restricted areas will be required to wear protective clothing. Emergency exit doors, which can only be opened from the inside, are provided in operating and storage areas.

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. 4 Non-routine maintenance on equipment will be initiated by a written work request form on which the person requesting maintenance describes the work to be done.

The requested maintenance project is approved by a member of management. For potentially high contamination area work the Facility Manager, Operations Manager, or Lead Shift Operator initiates the work by describing the work to be done on a Special Work Permit (SWP). The SWP defines procedures and special protective measures specifically for the job, and which are under the surveillance of the Health Physicist. Personnel and equipment exiting the restricted areas will be surveyed to determine if they meet the unrestricted area limit.

Contamination surveys will be conducted routinely and a system of permanently-mounted gamma monitors and air samplers will be operated during VRDF operations to ensure waste confinement. (See Section 7 of this report for a description of the monitoring program. )

5.1.6.2 Inventory Control A computerized inventory control and tracking system would be used to adminis-tratively track and classify processed material. This system would process and be the basis for maintaining the records and preparing the manifests required by 10 CFR 20.311. This regulation describes the manifests required for waste processors who treat or repackage waste, as well as the manifests and labelling required for shipping waste to a licensed disposal site.

Staging areas would be structured to allow the accumulation of quantities of incoming material sufficient to permit efficient processing of a generator sponsor's batch in the incinerator. Each generator sponsor's waste would be accumulated, then tracked and processed separately from other generator's waste and either returned to the generator, or disposed in a licensed LLW disposal facility as that generator's waste.

The generators would describe the contents of the waste containers and the VRDF would accept this description. However, all packages will be visually inspected, surveyed for gamma activity and selected ones will be smeared for surface con-tamination. In addition, packages from each shipment will be selected randomly for whole package counting to check TRU content. Each container is checked against the shipping manifest and is logged into a computer system to maintain waste identity through all facility operations.

5.2 Effluent Control Sections 5.2.1 through 5.2.3 describe the potential sources of radioactive and nonradioactive effluents in the VRDF. The equipment and operations to manage those effluents will also be described. The environmental effects that would result from these effluents, and the program that would monitor these effluents are discussed in Sections 6 and 7, respectively.

5.2.1 Gaseous Effluents Sections 5.2.1.1 through 5.2.1.5 describe the potential VROF gaseous effluents and their treatments. Also included is a discussion of the overall ventilation system in the VRDF.

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O 'o 5.2.1.1 Waste Loading The principal source of airborne radioactive material in the waste loading opera-tion would result from the entrainment of radioactive material in air that is carried through the charging lock. The airborne radioactivity would be contained by the waste loading chambers. Air from these chambers is drawn into a local exhaust system that connects with the cooling air inlet to the incinerator mixing chamber. This gas steam passes, with process flue gas, through a set of roughing filters followed by HEPA filters and exits to the atmosphere through the flue gas stack.

5.2.1.2 Incinerator The incinerator off gas would pass through the off gas cleanup system prior to begin released to the atmosphere through the incinerator stack.

The off gas cleanup would operate as follows. The hot incinerator off gasses are drawn through a hot gas filter, a mixing chamber, a set of mesh filters, roughing filters, and finally HEPA filters before being discharged via the flue gas stack. The purpose of the mixing chamber is to cool the process gases by drawing air from rooms, waste loading chambers, mesh filter housing, and ash loading chambers into the off gas stream.

5.2.1.3 Ash Handling The principal source of airborne radioactive material in the ash handling opera-tion would result from entrainment of radioactive material in the air of the ash discharge locks. These locks are located at the incinerator, hot gas. filter, and the mesh filter. All of these locations are served by ash discharge locks ,

that are provided with controlled ventilation through local vents to an exhaust system. As in the case of waste loading, the exhaust system connects with the cooling air inlet to the incinerator mixing chamber. The exhaust system gas is treated as a part of the incinerator off gas stream as described above. -

5.2.1.4 Compensating Vessel l The compensating vessel is a vertical, cylindrical steel tank lined with hard l rubber whose function is to provide passive backup protection against potential releases resulting from the incinerator pressure becoming positive relative to the atmosphere (see figure 3.2). The water level is maintained automatically in the vessel to make up for evaporative losses; low and high-limit level switches control the addition of water. A 16-in. diameter flue gas duct connects the incinerator combustion chamber to the vessel, and this duct projects below the surface of the water. The discharge of the compensating vessel is connected by ducting directly to the filtered building exhaust system.

5.2.1.5 Ventilation System

, The facility is serviced by process and building ventilation systems that'are l exhausted through exterior stacks. Ventilation air is supplied to and exhausted l from each building separately. Figure 5.1 schematically illustrates the VRDF j building ventilation system. As shown, the air from the Waste Storage Building is not filtered before it is exhausted through the building roof vent. All air from rooms in the Process Building is exhausted through HEPA filters, either 5-7

4 To Flue Building Vent Roof Stack Gas Stack Air from Outside A h 1 Hominal Nominal 1000 5370 scfm ,

scfm

' LUl Storage Building , ,

i i G45 l l 9 HEPA HEPA

, liter Filte Motor Control Center ,

Control Room, A h Locker Areas Other Areas %

as Necessary f_+

. Mesh

• Compensating + I Vessel Filter By-Pass l,

y l Duct h "

Equipment Areas l Exhaust System 1

Cooling y Y g ly Mixing Chamber I i Air )

i l'IL_____q j y n h By-Pass llaste Charging Room .i l

~

Hot Gas Filter, s

I g, t[+

HEPA Filters, and Fan Rooms m Incinerator a I p f Hot Y

Gas Filter i Ash Discharging Room >

Incinerator Room- 7 a

Figure 5.1 VRDF ventilation schematic 5-8

....,., _ -.-.-...17_, . .. - --

- -. .,... - - 1

. y through the normal room ventilation or by way of the process off gas cleanup system.

The building heating, ventilation, and air conditioning (HVAC) system is designed to confine and move airborne radioactive particulate matter to treatment systems and away from personnel. Air flow is established by pressure differential controls such that air is routed from clean zones to progressively more con-taminated zones, e.g., from unrestricted ar.eas to operating or maintenance areas to process. Other than process off gas, other ventilation and filtered air streams are discharged at building level. Ventilation is provided on a once-through basis. All fresh air supplies are filtered. Operating areas are sup-plied with approximately 5 air changes per hour. Systems areas are designed to ensure ventilation balance, contamination control, and maintenance of pressure differentials. Filters are designed for bag out operations with adequate working space. Filters are monitored continuously for pressure drop, and periodic surveys of radioactivity levels are made.

5.2.2 Liquid Effluents Sections 5.2.2.1 through 5.2.2.3 describe the potential sources and treatment of radioactive and nonradioactive liquid effluents.

5.2.2.1 Process Water Water used at the facility site originates from the existing Battelle water

supply. Process water is required for the quench cooler and for the compensating l ' vessel (for make-up, as recessary). Water for the quench cooler is evaporated in the process air that is recirculated t,o the incinerator pyrolysis chamber. l It then passes as water vapor through the process off gas cleanup system. '

The compensating vessel

• provides the ability to relieve any short term over-pressure impulses within the incinerator system without permanently destroying the incinerator seal. The water column in the tank acts as a seal to maintain the negative incinerator system pressure during operation. In addition, it acts as a cooling medium for the hot gas in the unlikely event of a system upset which could cause hot process gas to be released directly from the incinerator.

Any contaminated water from this vessel would be disposed of in the quench cooler l in the stead of using plant water. Its disposition would be as discussed above. -

t 5.2.2.2 Drains and Sewage System '

f Floor drains in waste processing areas will be plugged; any cleanup required j during normal operations will be accomplished by dry methods or with special wet equipment. Any accumulated fire protection water will be sampled for analysis of radioactivity concentrations. This retained water will then be disposed of appropriately, either by discharge through a drain system to a surface outfall ditch or by evaporation to reduce the volume of radioactive material for disposal with other on-site low-level waste to burial.

l

' The waste storage areas will not have drains; cleanup will be effected dry or ,

with special wet equipment. Drains in non-waste areas will be directed to a

, surface outfall trench. Storm drains, installed to provide drainage from all roof areas of the building and areas adjacent to the building, will be channeled to surface outfall ditches.

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The facility will use about 1 gpm of water for domestic uses, including potable water and water for sanitary facilities. The sanitary wastes, sink drains, and showers at the facility will be piped to the existing Battelle system for treat-ment. The design and operation of the sewage treatment plant will be in accor-4 dance with all applicable local, state and federal codes.

5.2.2.3 Laundry Protective clothing, consisting of coveralls, lab coats, hoods, caps, gloves and masks, will be laundered by an outside service equipped to handle the laun-dering requirements of the facility. Used protective clothing will be monitored, bagged and transported to the laundry facility. Cleaned, released laundry will be returned to the facility supply room.

5.2.3 Solid Wastes 4

The only solid waste with radioactive content produced by the incineration pro-cess would be~ noncombustible material separated at ash handling points described in Section 5.1.4.3 or separated from incoming waste at the waste loading station.

All the solid waste would be processed separately according to generator, drummed, and disposed of in a licensed LLW disposal facility, or returned to the generator.

The U.S. EPA has promulgated regulations governing the identification, management and disposal of hazardous wastes for the purpose of implementing the Resource Conservation and Recovery Act (RCRA). Requirements for " Identification and i Listing of Hazardous Wastes" are contained in 40 CFR Part 261 . Recently, it has been suggested that certain iLW could potentially be classified as hazardous according to 40 CFR Part 261. Consequently, concerns have emerged regarding the applicability of EPA regulations and permit requirements to chemical con-stituents present in LLW, and the appropriate methods for managing such wastes.

As % result the product ash from the VRDF should be characterized. The staff's

! judgment is that the ash will have r.either ignitable, corrosive, nor reactive characteristics as defined in 40 CFR 261 Subpart C. There is a remote possibil-ity that the solid waste exhibits the characteristic of extraction procedure (EP) toxicity, for example cadmium, chromium, and lead as contaminants that exceed EPA specified maximum concentration.

5.3 References

1. Report on Safety Related Information for the Battelle Volume Reduction Demonstration Facility, Battele Columbus Laboratories and ATCOR Engineered Systers Inc., April 15, 1983 (Appendix G to Renewal Application BCL-1081).

2. Code of Federal Regulations, Title 40, Protection of Environment, Parts 190 to 399, revised as of July 1, 1984, i

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6.0 ENVIRONMENTAL EFFECTS OF NORMAL FACILITY OPERATIONS AND TRANSPORTATION The radiological and nonradiological impacts that would result from normal facility operations and associated transportation activities are discussed in this section. Radiological impacts would include exposures resulting from airborne and liquid radioactive effluents, direct radiation exposure to the workers and the surrounding population, and exposures resulting from normal, incident-free transportation. Nonradiological impacts would include the effects of nonradioactive atmospheric emissions on the surrounding population, chemical exposure of the operators, and transportation related effects.

Terrestrial, aquatic, socioeconomic, and land and water use impacts are also addressed.

6.1 Radiological Effects from Operations The environmental impacts that would result from the normal operation of the VRDF with respect to radiological effects are discussed in this section. Sec-tion 6.1.1 discusses the impact of the releases of radioactive materials into the atmosphere. This release pathway was judged to be the most important environmental impact of operation of the VRDF.

The BCL license amendment application is for the operation of one incinerator and its attendant support facilities. For purposes of NRC staff evaluation, the incinerator was assumed to operate 7200 hours0.0833 days <br />2 hours <br />0.0119 weeks <br />0.00274 months <br /> per year on 330 pounds per hour of equal quantities of reactor and industrial / institutional waste.

Also discussed in this section are the effects of liquid effluents, radiation exposure to workers and to the population, and radiological impact on biota.

6.1.1 Airborne Effluents Operation of the incinerator facility would provide a pathway for release of radioactive materials to the environment. Systems have been designed into the

, incinerator facility to mitigate this release; however, these systems do not ef-l fectively trap nuclides that have been volatilized. Certain species of radionuclides become volatilized in high temperature oxidizing environments such as an incinerator. Reference 1 points out that up to 35 percent of cesium present in such an environment may be volatilized. Other nuclides of interest to this study that are expected to be volatilized are tritium, carbon-14 and iodine. These radionuclides might be completely transformed into vapor.

Volatilization is of special importance since filtration systems with high efficiencies for particulates have reduced efficiencies for volatilized mater-ials. Input material characteristics and activity concentrations are described in Chapter 4 of this report. Table 6.1 details the curie content of input material to the VROF incinerator.

The annual volumetric input to the incinerator was derived from the design cap-acity of 330 pounds of waste per hour operating 7200 hours0.0833 days <br />2 hours <br />0.0119 weeks <br />0.00274 months <br /> per year at the aver-age density of the materials fed to the Juelich incinerator over the four year period from 1979 through 1982. Equal volumes of waste from nuclear power plants and institutional / industrial generators were assumed to be processed in the incinerator facility.

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e Table 6.1 Annual Curie Content of Input to Incinerator (Based on 132,500 Cubic Feet Volume Per Year)

Activity Conc. Activity Conc.

Nuclide Reactor Institutional Reactor (Ci) Institutional (Ci) 4 (mci /ft3 ) (mci /ft3 )

Cr-51 2.9E-02 3.8E00 Mn-54 6.4E-02 8.5E00

.; Co-58 5.9E-01 7.8E01 Co-60 7.9E-01 2.9E-01 1.05E02 3.8E01 Sr-90 9.9E-04 4.1E-02 1.3E-01 5.4E00 Zr-95 9.9E-03 1.3E00 Ru-106 7.9E-03 1.0E00 Sb-125 1.9E-03 2.5E-01 Cs-134 1.2E-01 1.59E01 Cs-137 3.1E-01 1.3E-01 4.11E01 1.72E01 H-3 2.6E-02 2.6E+00 3.45E00 3.45E02 C-14 9.5E-04 1.5E-01 1.3E-01 1.99E01 1-125 1.6E-01 2.12E01 Am-241 1.4E-04 1.9E Tc-99 9.6E-08 1.3E-05

, The air ventilation system serving the incinerator facility would be operated at a negative pressure differential drawing all exhaust air through the filtration system. The annual releases that would be expected from the VROF were calculated by multiplying the number of curies to be processed by the VRDF by the overall decontamination factor (DF) of the process. All tritium, carbon-14 and iodine

- would pass through the filter system. Table 6.2 shows the estimated annual release resulting from wastes incineration at the VROF.

The DF values shown in Table 6.2 recognize no removal of H-3, C-14, or I-125 i in the process stream. Cesium-134 and Cesium-137 are filtered only after air

dilution reduces the process gas stream temperature to below 480*F (~250*C).

j. The maximum concentration of gaseous effluent at ground level was calculated by l selecting the sector with the highest annual average dispersion (X/Q) value (west of the site) using an elevated release. Because of the effects of the 130 foot stack, the point of maximum ground level concentration occurs about 1000 feet from the point of release, which coincidentally is near the site boundary. This concentration represents the highest concentration of airborne '

radioactive material in an unrestricted area. Table 6.3 lists the activity l emitted to-the atmosphere and the maximum concentration in an unrestricted area.

l Table 6.3 lists the total releases from processing all material in the incinera-tor facility and compares the radioisotope concentration at the point of maximum ground level concentration with the limits set forth in Chapter 10 of the Code of Federal Regulations Part 20. This table shows that releases from this fa-cility would be low and that maximum annual airborne concentrations, with the 6-2 r

e v- g -nvy, 4-- -m--m- , - - , . - , ..,rw ,--

Table 6.2 Annual Incinerator Releases from Combined Waste Input

Release Nuclide Input DF Release . Concentration

• Ci pCi pCi/ml i Cr-51 3.8E00 1.35E-06 5.1E00 7.8E-14

. Mn-54 8.5E00 1.35E-06 1.1E01 1.7E-13 Co-58 7.8E01 1.35E-06 1.1E02 1.7E-12 Co-60 1.43E02 1.35E-06 1.9E02 2.9E-12 Sr-90 5.5E00 1.35E-06 7.4E00 1.1E-13.

Zr-95 1.3E00 1.35E-06 1.8E00 2.7E-14 Ru-106 1.0E00 1.35E-06 1.4E00 2.1E-14

. Sb-125 2.5E-01 1.35E-06 3.4E-01 5.2E-15 Cs-134 1.59E01 1.5E-04 2.4E03 3.7E-11 Cs-137 5.83E01 1. 5 E-04 8.7E03 1.3E-10 H-3 3.48E02 1.00E00 3.48E08 5.3E-06 C-14 2.00E01 1.00E00 2.00E07 3.0E-07

.; I-125 2.12E01 1.00E00 2.12E07 3.2E-07

, Am-241 1.9E-02 1.35E-06 2.6E-02 4.0E-16

Tc-99 1.3E-05 1.35E-06 1.8E-05 2.7E-19 Table 6.3 Maximum Concentrations of Radionuclides at Ground Level from Normal VRDF Operations Max. Ground Limiting Ground Level Nuclide Release Rate X/Q Level Conc. Concentration Conc. as Percent pCi/sec sec/ml pCi/ml pCi/ml Limiting Conc.

Cr-51 1.6E-07 1.5E-11 2.4E-18 8.0E-08 3.0E-09 i Mn-54 3.5E-08 1.5E-11 5.3E-19 1.0E-09 5.3E-08 i Co-58 3.5E-06 1.5E-11 5.3E-17 2.0E-09 2.7E-06

! Co-60 6.0E-06 1.5E-11 9.0E-17 3.0E-10 3.0E-05 Sr-90 2.3E-07 1.5E-11 3.5E-18 3.0E-11 1.2E-05

. Zr-95 5.7E-07 1.5E-11 8.6E-18 1.0E-09 8.6E-07 Ru-106 4.4E-07 1.5E-11 6.6E-18 2.0E-10 3.3E-06 Sb-125 1.1E~08 1.5E-11 1.7E-19 9.0E-10 1.9E-08 Cs-134 7.6E-05 1.5E-11 1.1E-15 4.0E-10 2.8E-04 Cs-137 2.8E-04 1.5E-11 4.2E-15 5.0E-10 8.4E-04 H-3 1.1E01 1.SE-11 1.7E-10 2.0E-07 8.SE-02

C-14 6.3E-01 1.5E-11 9.5E-12 1.0E-07 9.5E-03 I-125 6. 7E-01 1.5E-11 1.0E-11 8.0E-11 1.3E-01 Am-241 8.2E-10 1.5E-11 1.2E-20 2.0E-13 6.0E-06 Tc-99 5.7E-13 1.5E-11 8.6E-24 2.0E-09 4.3E-13 4

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• exception of I-125, would be well below the 10 CFR 20 limits (less than 0.1 percent). The calculated concentrations are conservative to the extent that no credit has been taken for plume rise from the stack despite the high temperature (~475 F.) and velocity (~5500 SCFM) of the exit gas. Taking credit for plume rise would tend to move the point of maximum ground level concentra-tion away from the point of release and incur a lower value of X/Q.

6.1. 2 Liquid Effluents No radioactive liquid effluents would be generated during normal operation of the incinerator facility. The incinerator and its associated off gas treatment system would consume all liquids used in the system, therefore no liquid efflu-ents can be expected from normal operation of the incinerator facility. Loading, unloading, sorting and other processing operations would not result in effluents under normal conditions and therefore would not contribute to exposure of the population.

6.1.3 Radiation Exposures to Workers In operation of the VRDF, Battelle would have to comply with the provisions of 10 CFR Part 20, Standards for Protection Against Radiation, which provide limits for radiation axposure to workers. BCL also would have to comply with their own requirements for limitation of radiation exposure as far below the NRC limits as practicable, including a system for investigation of radiation exposure levels that are fractions of the annual limits.

• In Reference 2, Battelle showed that total exposure expected during normal oper-ations of the VRDF would be about 3 person-rems per year. For the six operators assumed by BCL this would result in an annual average radiation exposure of about 0.5 rem per operator. This value is less than the standard set forth in 10 CFR 20.101 (5 rems per year, 1.25 rems per quarter) and is consistent with the industry practice of designing an operation to achieve annual whole body radiation exposures in the range of 10-25 percent of the applicable limits.

Furthermore, the estimated exposure to workers has been corroborated by German experience that shows typical average annual exposures of 0.15 to 0.2 rem.3 The operator functions considered in the above estimates include waste feeding, ash drum removal, filter and refractory lining change, and routine repairs.

Other maintenance, where a radiation hazard is unavoidable, is controlled by j the previously described (Section 5.1.6.1) Special Work Permit.

! 6.1. 4 Radiation Exposure to the Population l Temporary on-site storage of large volumes of low-level waste would result in the potential exposure of nearby members of the population to external radi-ation from direct and scattered photons. Calculations were made to estimate these effects for a facility of similar capacity.4 Those calculations indicate the exposure rate from direct and scattered photons would be 3.3E-4 mrem /hr at a distance of 100 meters from the facility. This exposure rate is so low that the staff judged the effect to be negligible and thus deemed it unnecessary to calculate similar effects for the VRDF.

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The staff calculated the collective inhalation dose to the population within 50-miles of the 8CL VRDF and the dose to the maximally exposed individual.

These calculations were based on the release and concentration information shown in Table 6.3. The results of this analysis showed that the thyroid dose caused by the I-125 release was overwhelming-about 2 rem to nearest resident.

BCL had recognized this fact 4 and stated that "A careful schedule for incinera-tion of medical wastes will be developed to hold annual emissions of I-125 to approximately 10 mci." The staff findings are in general agreement with the BCL conclusions both in terms of radiation exposure and in the need to limit I-125 releases.

The NRC recalculated the exposure levels for the population and the nearest resident on the same bases as above, with the exception that I-125 release was limited to a maximum of 10 mci per year. The dose to the maximally exposed individual, defined as the individual located at the residence in the region of maximum off-site emissions, was assessed. The resultant doses to this indivi-dual from all important pathways of exposure are presented in Table 6.4. The doses calculated in this table are for an individual located at the actual residence receiving the maximum annual exposure and not for the hypothetical person located at the site boundary. The maximally exposed individual is deter-mined to be located at 2500 feet from the site in the northwest direction. The dose calculations used in Table 6.4 assumed that the maximally exposed indivi-dual residing at that location received an expo ~sure 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week, for the entire year. In addition, the ingestion pathway doses assumed that over half of the vegetation consumed by the individual was grown at the residence.

For comparison, the Environmental Protection Agency (EPA) Clean Air Act stan-dard in 40 CFR 61 limits to 25 and 75 mrem per year the public whole body and thyroid doses, respectively. Both the whole body and thyroid doses are sub-stantially below these limits.

The total dose expected from normal facility operation was calculated for the population within fifty miles of the VRDF. The whole body dose received by the surrounding population due to airborne emissions from the VRDF was estimated to be 29 person-rem per year. Due to the conservative nature of the assumptions used in making this analysis, actual doses would be significantly less. The same population will be exposed to a dose of about 230,000 person-rem per. year due to natural background radiation.

6.1. 5 Transportation 6.1. 5.1 Radiological Impacts This section discusses the radiological impact of the transportation of LLW through the area surrounding the VROF. Specifically, the impacts of routine shipments of both incoming waste and outgoing product are assessed for the gen-eral population and a maximally exposed individual. The area over which impacts are assessed consists of areas along the route between the site and the junction with the nearest interstate highway. Only normal (i.e. , incident-free) travel is considered here. The effects of transportation accidents are assessed in Section S. The NRC has previously determined that the environmental impacts of i

transportation of radioactive materials are sufficiently small to allow continued shipments by all transport modes.s 6-5

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' Table 6.4 Annual Dose to Maximum Individual Offsite* from Normal Operations Pathway Dose Commitment (mrem / year)

Total Body Thyroid Ground 0.14 0.14 Ingestion Vegetation 0.34 2.5 Meat 0.19 0.7 Milk 0.28 3.3 Inhalation 0.11 0.1 Total 1.1 6.7 Limits 10 CFR 20 500 N.A.

40 CFR 61 25 75

^

Location of nearest residence (not site boundary) - 2500 feet NW X/Q - 3.9E-06 Pathway sources - located at nearest residence Growing season factor - 0.5.

This assessment, is based on 180 shipments of LLW received annually, and 12 shipments of volume-reduced product sent back to the generator or to authorized disposal sites. All shipments, whether incoming or outgoing, will enter and leave the site on the one-mile stretch of State Route 142 that connects the l site with U.S. Interstate Route I-70.

l The dose to the maximum individual was assessed by assuming that this individual was located at a distance of 10 meters from State Route 142 on which all ship-ments passed at a speed of about 15 miles per hour. No credit was taken for shielding by structures. The dose rates from waste shipments would be in accor-dance with 10 CFR 71.47(c); not exceeding 10 mrem per hour at two meters from l the surface of the vehicle. Under these conditions the maximum individual whole l body dose would be 0.082 mrem per year. This is about 0.06 percent of the dose l

attributable to natural background radiation. On the basis that the maximum individual exposure due to transportation was so low, less than 0.1 mrem per year, the staff deemed the exposure to the general population to be an insig-nificant contribution to that previously determined.5 6.2 Nonradiological i.apacts The nonradiological impacts that would result from normal facility operations are discussed in this section. Taken in aggregate, these impacts would be small.

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O D 6.2.1 Site Preparation and Construction The incinerator facility will be constructed on a 1000-acre tract of land owned 4

by BCL. It will be located just outside the 10-acre fenced Nuclear Sciences area that is reserved for facilities such as the VRDF. The building floor area will occupy about 4800 sq. ft., or about 0.01 percent of the BCL-owned tract.

The building will be fabricated on grade with minimal excavation - only that required for foundation and footers. The contour and grade of land away from the building will not be altered. Access to the facility will be controlled by i

suitable fencing that surrounds the VRDF. Thus, the staff judges that the environmental impacts from facility construction would be small.

, 6.2.2 Facility Operations 6.2.2.1 Operational Releases to the Atmosphere Operation of the incinerator facility is not expected to generate significant nonradiological airborne hazards. Several arguments support this conclusion.

The proposed incinerator for the VRDF is an improved version of a prototype for which several years of operating experience have accrued.8 During operation chlorine, sulfur dioxide, and nitrogen oxide concentrations in the off gas "were considerably below the already very low release limits of the German TA regula-tions.ns Table 6.5 is a comparison of US EPA Primary Air Quality Standards and Federal Republic of Germany TA Luft standards.

Table 6.5 Comparison of Primary Annual Mean Air Quality 5tandards in mg/cu.m.

Contaminant USEPA German TA Luft Sulfur Dioxide 80 100 Particulate 75 100 Carbon Monoxide (8-hour) 10 100 Ozone (1-hour) 235 -

Nitrogen Dioxide 100 300*

Chlorides Hydrogen Chloride 170 Chloride Compounds 50 Fluoride Compounds -

2 .

"For municipal size power plants BCL will resubmit to Ohio EPA its application for a permit to install new sources of pollution. The Director of Ohio EPA shall issue a " permit to install" if he determines that (among other things) the installation will not result in a viola-tion of effluent standards adopted by the United States Environmental Protection Agency. In order to a=sure compliance with effluent release standards BCL intends to conduct trial burns before initiating full-scale, experimental incineration operations. The off gas stream will be sampled for chemical pollutants. Sampling frequency will be based on program phases and waste feed composition to gather data for the demonstration program and to support regulatory compliance.

6-7

• w Appendix A contains a discussion of dioxin, its toxic effects, regulatory status, formation, methods of measurement, and the potential for dioxin formation during operation of the VRDF.

6.2.2.2 Operational Effects on the Terrestrial Environment Impacts to the terrestrial environment are judged to be limited to an increase in traffic in the area of the plant. The addition of one truck shipment every two days would not significantly affect the life and repair of State Route 142.

It is anticipated that the quality of the road would remain about the same, witn or without the extra shipments. Traffic increases of this nature are associated with all modern industrial activities. The environmental impact from normal operations would be small.

6.2.2.3 Operational Effects on the Aquatic Environment Operation of the incinerator facility are judged to have no significant impact on the quality of the aquatic environment.

6.2.2.4 Social and Economic Effects The VRDF is expected to have a positive economic effect through the limited employment the facility brings to the area. The facility is not expected to pose substantial additional demands for public or social services or economic resources.

6.3 Imoacts on Land Use Recognizing that the preferred method of decommissioning the facility is complete dismantlement, the VRDF would not permanently commit any land resources and it was judged to have no significant impacts on land use.

6.4 Impacts on Water Use The VRDF is designed to operate without the use of any significant amounts of water. Therefore, the VRDF would not discharge any significant quantities of liquid wastes. Consequently there will be no significant impacts on water use.

6.5 Decommissioning Decommissioning of the facility is not expected to have significant impact. -

Since the facility would handle only LLW, high personnel exposures would be unlikely. Although the preferred method of decommissioning is complete disman-tlement, Battelle is studying the alternatives of continued operation as a '

nonradioactive research facility; decontamination, sale and transfer; or lease

, for continued radioactive waste incineration.7 The ultimate decommissioning plan will be submitted for review by the NRC.

The large resources of BCL would be available to insure that all necessary decommissioning work would be accomplished. Decommissioning the VRDF is not "

expected to result in an adverse environmental effect.

The financial plan for decontamination and decommissioning of the LLW incinera- ,

tion facility is described in the BCL Renewal Application BCL-1081, Part I, Section 5.2.

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6.6 References

1. Vaughen, U.C.A., et al., Hot-Cell Evaluation of the Burn-Leach Method for Reprocessing Irradiated Graphite-Base HTGR Fuels, ORNL-4120, February 1970.

2. Report on Safety Related Information for the Battelle Volume Reduced Demonstration Facility, Battelle Columbus Laboratories and ATCOR Engineered Systems, Inc. , April 15, 1983 (Appendix G to Renewal Application BCL-1081).

3. Frecher, P. A., Juelich Research Center, letter to Kraftenlagen, June 22, 1983.

4. Environmental Assessment of Babcock & Wilcox Volume Reduction Services Facility, Parks Townsnip, Pennsylvania, (Docket 70-364), U.S. Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards, March 1986.

5. Final Environmental Statement on the Transportation of Radioactive Material i

by Air and Other Modes, NUREG-0170, U.S. Nuclear Regulatory Commission, December 1977.

6. Incineration of Radioactive Wastes Applying the "Juelich Incineration Process," Manfred Wilke and Klaus Fatho, Heidleberg, April 1981.

7. Report on Environmental Assessment for Demonstration Incineration Operations, Battelle Columbus Laboratories, August 15, 1983. (Appendix H to , Renewal j Application BCL-1081)

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

.- s.

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7.0 DESCRIPTION

OF OCCUPATIONAL AND ENVIRONMENTAL MONITORING PROGRAMS The occupational and environmental monitoring programs are described in Sec-tions 7.1 and 7.2, respectively. The programs described here supplement the occupational and environmental surveillance programs that are specified in the existing BCL license. Part I, Section 3.0 of the license renewal application 1  !

describes the criteria necessary to keep both levels of discharges of radio-active material from BCL facilities and equipment and levels of penetrating

, radiation on and about the site As Low As Reasonably Achievable (ALARA).

l l 7.1 Occupational Monitoring Program The monitoring programs described in this section are designed to measure radia-tion. These monitoring programs fall into two general categories: Those that ,

continuously measure radiation and provide immediate feedback on the quantity of radioactivity (sometimes called real-time monitoring); and those that require i

periodic (or sometimes continuous) samples be taken and analyzed later to mea-sure the quantity of radioactivity and sometimes specific radionuclides. Two of the programs that are planned at the VROF provide immediate feedback: Area gamma monitors in the storage area, change area, and operating areas, and con-

! stant air monitors in the waste charging and ash discharge areas (described in l Section 7.1.3). The second program is the external radiation monitoring activity

discussed in Section 7.1.4. In Section 7.2.1 another real-time system in the

VRDF is described - a continuous stack monitor to detect particulate emissions exceeding the concentrations in Appendix B of 10 CFR 20. The rest of the mon-I itoring programs that are planned at the VRDF are sampling programs where samples of air, vegetation, stack effluent, and swipes for removable contamination are taken and analyzed periodically.

7.1.1 Personnel Monitoring Personnel working in the VRDF would be issued thermo-luminescent dosimeters *

(TLD's) for whole body beta / gamma monitoring. In addition, specific dosimetry such as TLD finger rings and self-reading pocket dosimeters might be required.

The need for special dosimetry would be determined on a case-by-case basis as

the specific radiological safety precautions are established.2 l 7.1. 2 Contamination Surveys 3 During start up of waste reduction activities surveys for removable contamina-l tion would be performed at least daily. On the basis of the experience so gained frequency will be adjusted. During routine operations the contamination survey frequency would not be less than the present license limit of weekly. ,

! If the system is shut down for nonmaintenance reasons for a period exceeding l' one month, contamination surveys would be stopped and reinitiated at least one t week before resumption of operations.

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. - - - - - - . . . - - . - , -n---- , . - , , , . . - - - ~ . ., ,-- ---- . - - - - - - ~ ~ ~ - - - - - - - - - - - ' - - - - - - - - - ~ ~ ~

E

, o 7.1.3 Radiation Monitoring Continuous air samplers (CAM) are provided in staging and loading areas, and ash removal areas. Gamma monitors are located in the staging and loading area, filtration system area, and the ash removal area. Hand-held gamma monitors are available in the incoming waste storage area, the combustion chamber area, and the ash storage area. The frequency of analysis of CAM filters is to be the same as that for contamination surveys (see Section 7.1.2 above).

7.2 Monitoring of Effluents to Atmosphere 7.2.1 Stack Monitoring BCL has proposed that the VROF building ventilation system stack effluents would be sampled continuously and analyzed at least weekly for alpha and beta-emitting particulate. In addition, BCL plans weekly analyses of continuous samples for tritium and . carbon-14 to confirm that the incinerator effluent treatment system is operating effectively and to confirm estimates of carbon-14 and tritium releases based on shipping manifest data. Tritium and carbon-14 release rates would be measured until sufficient data exist to show that the concentrations reasonably agree with, or are typically lower than, release rates estimated from shipping manifest data.

A generator's responsibility is to have accurate manifests. However, BCL must assure that generators' records accurately and completely reflect shipments in order to keep releases within BCL's administrative annual limits. To provide additional assurance, the NRC staff will require that particulates, tritium, carbon-14, and iodine-125 be fampled continuously and analysed on a daily basis, not just when shipping manifest data indicate that specific isotopes exist in the waste, unless verification is made of generators' authorized radionuclide possession. If only reactor waste is processed, daily analyses for particulates and weekly analyses for tritium and carbon-14 will be required.

7.2.2 Environmental Monitoring Program In additional to the routine monitoring of liquid and atmospheric emissions at the West Jefferson site, BCL collects data for ~ arious v environmental media including air, water, grass, fish, food crop, sediment and soil from the area surrounding the site. In 19844, besides gross alpha and gross beta determina-tions, the activities of nineteen different radionuclides were measured in the air and water effluents from the BCL West Jefferson site. From the start of operations of the VROF BCL intends to incorporate into their environmental monitoring program an evaluation of dose from I-125 based on deposition asso-

. ciated with vegetation.3 l

7.3 References I

1. Battelle Columbus Laboratories Renewal Application for Combined Special l Nuclear Material and Byproduct License, Renewal Application BCL-1081, Revised August 1, 1981, Part I.

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2. Report on Safety Related Information for Battelle Volume Reduction Demonstration Facility by Bettelle Columbus Laboratories, Columbus, Ohio and ATCOR Engineered Systems, Inc. Avon, Connecticut; August 15, 1983.

(Appendix G to Renewal Application BCL-1081).

3. Telecopy of Letter from H. Toy, Battelle, to J. E. Ayer, NRC, Dated 25 April 1985.

4. BCL-5184, Environmental Report for Calendar year 1984 on Radiological and Nonradiological Parameters to United States Department of Energy, Chicago Operations Office.

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8.0 IMPACT OF POTENTIAL ACCIDENTS IN FACILITY OPERATIONS AND TRANSPORTATION 8.1 Introduction For the purpose of environmental analysis, several accident scenarios have been selected to conservatively represent a spectrum of potential accidents that could occur. The described scenarios are considered conservative in terms of both accident potential and radiciogical consequences.

Each of the postulated accidents would involve only a fraction of the total facility and, therefore, only a fraction of the total radionuclide inventory.

Since the exact composition of the facility inventory is impossible to predict, two cases are postulated for each scenario: an entire inventory of all reactor i

material and an entire inventory of all institutional / industrial material.

In each case in this section, the maximum plausible inventory was assumed to be released as a result of an accident. Assumptions concerning release j fractions were based upon best judgments of the staff based upon specific j~ considerations of the physical conditions expected during the accidents and are felt to be realistic.

Impacts from the potential accidents are discussed in Section 8.2 and are summarized in Table 8.1. Sections 8.3.through 8.7 describe in detail the potential effects of an incinerator explosion, staging area fire, container rupture, transportation accident, and loss-of power off gas system accident.

References are given in Section 8.8.

, 8.2 Evaluation of Potential Environmental and Occupational Impacts of 4

Accidents *

• The radiological impact of accidents reviewed in the following sections are summarized in Table 8.1. There are no directly relevant numeric criteria for i

accident evaluation; however, the doses ;&*:ulated are fractional portions of the annual occupational limits prescrited t ' Title 10 of the Code of Federal Regulations (10 CFR 20).

The BCL Safety Related Information Report 1 (Section 6) contains accident analyses of the incinerator explosion, the staging area fire, and the container rupture.

l BCL's detailed results are included in the sections discussing these accidents

! for comparison and informational purposes. The BCL EA results were similar to, i but lower than, the results calculated by the NRC staff. Both the NRC and BCL

, assumed that the maximally exposed individual was the nearest actual resident in the region of maximum off-site emissions.

8.3 Incinerator l

l The design and operation of the incinerator was described in 3.2.5. Two j potential accident scenarios are described for the incinerator:

i l

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

, 3 Table 8.1 Summary of Whole Body Dose to Maximally Exposed Individual from Various Accident Scenarios 50 yr Dose Commitment Dose From From Inhalation Ground Deposition Accident mrem mrem /yr Incinerator Explosion Reactor Material 0.16 2.6 Institutional Material 0.15 0.04 Waste Storage Area Fire Reactor Material 0.13 2.1 Institutional 1. 0 0.76 Container Rupture Reactor Material 0.00094 0.016 Institutional Material 0.0011 0.0057 Transportation Accident Insignificant Not. Assessed Loss-o f-Power Reactor Material 0.018 0.023 Institutional Material 0.022 .

0.0084 8.3.1 Incinerator Explosion The incinerator design characteristics of the facility are such that even events such as the processing of a container of flammable liquid would not result in a l fire or explosion. The system is designed to shutdown automatically in the event I of malfunctions or abnormal situations. The standard design and operation of the l incinerator would accommodate potential overpressurizations through the compensating l vessel.

Nevertheless, an explosion that would affect the incinerator feed, entry, con-trol and preparation areas as well as the incinerator itself was assumed to occur. The probability for this event is considered small.

8.3.1.1 Radiological Effects For the case of reactor material, the total affected inventory was assumed to be equivalent to a one-hour charge. The number of drums of waste material, was converted to activity using an average density of 8.95 pounds per cubic foot and for both reactor waste and institution / industrial waste. Table 8.2 details the isotopic breakdown of released isotopes for the case in which inventory in the affected areas would be composed of entirely reactor material. The resulting inhalation dose is also reported for the maximally exposed individual to be l

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' s 0.16 mrem committed over 50 years. while the dose from ground-deposited Co-60 i radiation is about 2.55 mrem /yr. Table 8.3 lists the isotopic breakdown of released material in which the affected inventory is assumed to be composed entirely of institutional / industrial material. Inhalation dose to the maximally exposed individual is calculated to be 0.15 mrem committed over 50 years, and dose from ground-deposited Co-60 is about 0.94 mrem /yr. The scenario using reactor material was found to cause only slightly greater exposures in terms of inhalation and direct radiation doses delivered to the maximally exposed individual.

8.3.1.2 Comparison with BCL EA Accident Analysis Battelle did not present an explosion analysis in their safety analysis. They did, however, make an estimate of the results of a maximum hypothetical accident.

The BCL results were predicated on 10-second exposure to 100 mci of each of the several isotopes. They calculated that the 50 year dose to the lung of an individual 2500 feet away from the VRDF from Co-60 under average dispersion conditions would be 0.12 mrem. This compares with 0.16 mrem to the whole body, mainly contributed by Co-60, calculated by the NRC staff.

8.4 Waste Storage Area Fire A fire could occur in the Waste Storage Building. .The facility design includes an automatic heat-activated sprinkler system as a backup to any operator-initiated response. We conservatively assumed in this scenario, however, that all the incoming waste inventory would be involved.

'8.4.1 Radiological Effects The Waste Storage Building has the capacity to hold 550 drums of incoming waste.

One-half of the total capacity was assumed to be involved in the fire. This assumption was made to recognize such factors as availability of storage volume (the facility not being filled), non-combustible packaging, operation of the fire suppression system, etc. Thus, 275 drums of incoming waste is considered burned, each drum having a volume of 7.3 cubic feet. Based on previous estimates of fly ash production in incinerators, 1.5 percent of the inventory affected would be released to the atmosphere.2 Table 4.1 was used to calculate an iso-topic breakdown in the case in which the storage area inventory was composed entirely of reactor material. The resulting atmospheric releases and inhalation and ground deposition doses to the maximally exposed individual are listed in Table 8.4. Table 8.5 contains similar information for the case where inventory is composed entirely of institutional / industrial material.

! 8.4.2 Comparison to BCL EA Ac'cident Analysis The potential effects of a fire in the Waste Storage Building could be considered one of BCL's " maximum hypothetical" accidents. In this case, as in the incinerator explosion case, BCL would claim that the 50 year dose to the lung of an indi-vidual 2500 feet away from the VRDF from Co-60 under average dispersion condi-tions would be 0.12 mrem. This compares with the staff calculation of 1.02 mrem whole body of which nearly one-half is contributed by I-125.

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Table 8.2 Whole Body Dose to Maximally Exposed Individual from Incinerator Explosion Source Term: Reactor Material 36.9 cubic feet @ 100% release Activity Activity

• Dose Released X/Q Inhaled Factor Dose Nuclide mci sec/m3 mci rem /50y/ mci rem /50yr Cr-51 1.07E00 8.4E-05 3.1E-08 2.64E-01 8.2E-09 Mn-54 2.36E00 8.4E-05 6.9E-08 6.30E00 4.3E-07 Co-58 2.21E01 8. 4E- 05 6.4E-07 6.16E00 4.0E-06 .

Co-60 2.92E01 8.4E-05 8.5E-07 1.50E02 1.3E-04 Sr-90 3.65E-02 8.4E-05 1.1E-09 1.30E03 1.4E-06 Zr-95 3.65E-01 8.4E-05 1.1E-08 1.85E01 2.0E-07 Ru-106 2.92E-01 8.4E-05 8.5E-09 4.40E07 3.7E-06 Sb-125 7.00E-02 8.4E-05 2.0E-09 9.25E00 1.9E-08 Cs-134 4.43E00 8.4E-05 1.3E-07 4.80E01 6.2E-06 Cs-137 1.14E01 8.4E-05 3.3E-07 3.2E01 1.1E-05 H-3 9.59E-01 8.4E-05 2.8E-08 6.17E-02 1.7E-09 C-14 3.51E-02 8.4E-05 1.0E-09 2.31E-02 2.4E-11 Total Inhalation 1.6E-04

• Breathing Rate 3.47E-04 m3 /sec Ground Deposition Activity Dose Released X/Q Depostion Factor Dose Nuclide mci sec/m3 pCi/m2 rem m2 /yr pCi rem /yr Co-60 2.92E01 8.4E-05 2.45E04 1.04E-07 2.55E-03 I

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Table 8.3 Whole Body Dose to Maximally Exposed Individual from Incinerator Explosion Source Term: Institional Material 36.9 cubic feet @ 100% release Activity Activity

• Dose Released X/Q Inhaled Factor Dose Nuclide mci sec/m3 mci rem /50yr rem /50yr Co-60 1.07E01 8.4E-05 3.12E-07 1.50E02 4.68E-05 Sr-90 4.39E-01 8.4E-05 1.28E-08 1.30E03 1.66E-05 Cs-137 4.80E-01 8.4E-05 1.40E-08 3.20E01 .

4.48E-07 Tc-99 3.54E-06 8.4E-05 1.03E-13 8.33E00 8.60E-13 Am-241- 5.17E-03 8.4E-05 1.51E-10 4.62E05 6.96E-05 H-3 9.59E02 8.4E-05 2.80E-05 6.27E-02 1.72E-06 C-14 5.54E00 8.4E-05 1.61E-07 2.31E-02 3.73E-09 I-125 5.90E00 8.4E-05 1.72E-07 9.25E01 1.59E-05 Total Inhalation 1.51E-04

^8reathing Rate 3.47E-04 m3/sec Ground Deposition Activity Dose Release X/Q Deposition Factor Dose Nuclide mci sec/m3 pCi/m 2 rem m2 /yrpCi rem /yr Co-60 1.07E01 8.4E-05 8.99E03 1.04E-07 9.35-04 i

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Table 8.4 Whole Body Dose to Maximally Exposed Individual from Fire in Waste Storage Building Source Term: Reactor Material 2000 cubic feet @ 1.5% release Activity Activity

• Dose Release X/Q Inhaled Factor Dose Nuclide mci sec/m3 mci rem /50yrmCi rem /50yr Cr-51 8.70E-01 8.4E-05 2.54E-08 2.64E-01 6.69E-09 Mn-54 1.92E00 8.4E-05 5.60E-08 6.30E00 3.53E-07 Co-!.8 1.80E01 8.4E-05 5.25E.07 6.16E00 3.23E-06 Co-60 2.37E01 8.4E-05 6.91E-07 1.50E02 1.04E-04 Sr-90 2.97E-02 8.4E-05 8.66E-10 1.30E03 1.13E-06 Zr-95 2.97E-01 8.4E-05 8.66E-09 1.85E01 1.60E-07 Ru-106 2.37E-01 8.4E-05 6.91E-09 4.40E02 3.04E-06 Sb-125 5.70E-02 8.4E-05 1.66E-09 9.25E02 1.54E-06 Cs-134 3.60E00 8.4E-05 1.05E-07 4.80E01 5.04E-06 Cs-137 9.30E00 8.4E-05 2.71E-07 3.20E01 8.67E-06

. H-3** 5.20E01 8.4E-05 1.54E-06 6.17E-02 9.53E-08 C-14** 1.90E00 8.4E-05 5.54E-08 2.31E-02 1.27E-09 Total Inhalation 1.26E-04 -

• Breathing Rate 3.47E-04 ma /sec

• • 100% release Ground Deposition Activity Dose Release X/Q Deposition Factor Dose Nuclide mci sec/m3 pCi/m2 rem m2 /pCfyr rem /yr Co-60 2.37E01 8.4E-05 1.99E04 1.04E-07 2.07E-03 l

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. V Table 8.5 Whole Body Dose to Maximally Exposed Individual from Fire in Waste Storage Building Source Term: Institutional Material 2000 cubic feet @ 1.5% Release Activity Activityd Dose Release X/Q Inhaled Factor Dose Nuclide mci sec/m3 mci rem /50yrmCi rem /50yr Co-60 8.70E00 8.4E-05 2.54E-07 1.50E02 3.80E-05 Sr-90 1.23E00 8.4E-05 3.59E-08 1.30E03 4.66E-05 Cs-137 3.90E00 8.4E-05 1.14E-07 3.20E01 3.64E-06 Tc-99 2.88E-06 8.4E-05 8.39E-14 8.33E00 6.99E-13 Am-241 4.20E-03 8.4E-05 22E-10 4.62E05 5.66E-05 H-3** 5.20E03 8.4E-05  :. 52E-04 6.17E-02 9.35E-06 C-14** 3.00E02 8.4E-05 8.74E-06 2.31E-02 2.02E-07 I-125** 3.20E02 8.4E-05 9.33E-06 9.25E01 8.63E-04 t

Total Inhalation 1.02E-03

• Breathing Rate 3.47E-04 m3 /sec

• • 100% release Ground Deposition Activity Dose Released X/Q Deposition Factor Dose Nuclide mci sec/m3 pCi/m2 remm 2 /pCiyr rem /yr a Co-60 8.7E00 8.4E-05 7.30E03 1.04-07 7.6E-04 8-7

8.5 Container Rupture Containers of waste material would be moved about the facility by forklift, crane and conveyor. In this scenario, a container is ruptured by either drop-ping or puncturing the container. The containers assumed in this scenario are those with the highest potential activity. Only one container is ruptured, and 0.1 percent of the material reaches the environment. The 0.1 percent release assumption is very conservative (about 7 percent of that released by fire) and should only be used to provide a relative perspective on the significance of such scenarios. Although supporting references for such release fractions have not been found, releases from ruptured containers would be expected to be orders of magnitude below the 0.1 percent values presented in the analysis.

8.5.1 Radiological Effects

~

For the case of reactor materials, the " limiting" case would be one 55 gal, drum of incinerator product equivalent thirty volumes of incoming reactor material. For institutional / industrial material, iodine-125, tritium, and carbon-14 would not be present in the incinerator ash because they would be totally volatilized during incineration. The container rupture scenario is considered to occur in the Waste Storage Building because it has an unfiltered ventilation system, which leads to maximized effects. The conservative assump-tion that 0.1 percent of the material reaches the environmental yields total activities released along with the inhalation and groundshine doses to the maximally exposed individual as listed in Tables 8.6 and 8.7.

8.5.2 Comparison to BCL EA Accident Analysis Battelle analyzed for the effects of an ash spill in the Process Building, which is served by HEPA exhaust filtration. In so doing they correctly fopused on operator exposure but neglected to address the environmental effect. .The NRC staff conservatively estimated that an ash spill due to container puncture in the unfiltered atmosphere of the Waste Storage Building would yield a total body 50 year dose commitment of about 10 3 mrem to the nearest resident from either reactor or institutional wastes.

8.6 Transportation Accident The environmental impact of radioactive shipments in all modes of transport in the United States, under the regulations in effect as of June 30, 1975, have been documented in NUREG-0170. The potential for radiological exposure to transport workers and to members of the general public due to transportation accidents was assessed. The expected values of the annual radiological impact t

from such potential exposure were estimated to be about one latent cancer fatality and one genetic effect for 200 years of shipping at 1975 rates. The shipping rates for the VRDF are estimated to be 15 shipments per month of LLW into the facility and 1 truckload per month of ash leaving the facility. The environmental impact of transportation of LLW to the VRDF and incinerated product from the VRDF is a disappearingly small fraction of that attributed to 200 years of radioactive shipments at 1975 rates. Therefore, the staff judged that the fractional impact of U.S. radiological material transportation attributable to VROF operation is so small as to be insignificant.

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. l Table 8.6 Whole Body Dose to Maximally Exposed Individual from Ash Container. Rupture Source Term: Reactor Material 225 cubic feet @ 0.1% release Activity Activity Dose Released X/Q Inhaled Factor Dose Nuclide mci sec/m3 mci rem /50yrmCi rem /50yr Cr-51 6.53E-03 8.4E-05 1.90E-10 2.64E-01 5.02E-11 Mn-54 1.44E-02 8.4E-05 4. 20E-10 6.30E00 2.64E-09 Co-58 1.35E-01 8.4E-05 3.93E-09 6.16E00 2.42E-08 Co-60 1.78E-01 8.4E-05 5.19E-09 1.50E02 7.78E-07 Sr-90 2.23E-04 8.4E-05 6.50E-12 1.30E03 8.45E-09 Zr-95 2.23E-03 8. 4E-05 6.50E-11 1.85E01 1.20E-09 Ru-106 1.78E-03 8.4E-05 5.19E-11 4.40E02 2.28E-08 Sb-125 4.28E-04 8.4E-05 1.25E-11 9.25E00 1.15E-10 Cs-134 2.70E-02 8.4E-05 7.87E-10 4.80E01 3.78E-08 Cs-137 6.98E-02 8.4E-05 2.03E-09 3.20E01 6.51E-08 Total Inhalation 9.40E-07

• 8reathing Rate 3.47E-04 m3 /sec l

Ground Deposition

• Activity Dose Released X/Q Deposition . Factor Dose Nuclide mci sec/m3 pCi/m2 remm 2 /pClyr rem /yr Co-60 1.78E-01 8.4E-05 1.50E02 1.04E-07 1.56E-05 8-9

.* 4 Table 8.7 Whole Body Dose to Maximally Exposed Individual from Ash Container Rupture Source Term: Institutional Material 225 cubic feet @ 0.1% release Activity Activity

• Dose Released X/Q Inhaled Factor Dose Nuclide mci sec/m3 mci rem /50yrmCi rem /50yr Co-60 6.53E-02 8.4E-05 1.90E-09 1.50E02 2.85E-07 Sr-90 9.23E-03 8.4E-05 2.69E-10 1.30E03 3.50E-07 Cs-137 2.92E-02 8.4E-05 8.51E-10 3.20E01 2.72E-08 Tc-99 2.16E-08 8.4E-05 6.30E-16 8.33E00 5.23E-15 Am-241 3.15-05 8.4E-05 9.18E-13 4.62E05 4.24E-07 Total Inhalation 1.09E-06

• Breathing Rate 3.47E-04 m 3/SEC Activity Dose Released X/Q Deposition Factor Dose Muclide mci sec/m3 pCi/m2 remm 2 /pClyr rem /yr Co-60 6.53E-02 8.4E-05 5.49E01 1.04E-07. 5.70E-06 0

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8.7 Loss-of-Power Accident An accident that assumes complete loss of electrical power to the facility was addressed. In such an occurrence, it was assumed that the total affected inventory would be a one-hour charge of material containing one-half of its radioactive constituents. It was further assumed that the bag filters and Hepa filters were breached due to hot process gas that is undiluted by inlet mixing gas. The process gas flow is induced only by the stack draft. Due to the low rate of flow it was assumed that the radioactive inventory on the bag filters and HEPA filters did not contribute significantly to the releases. The radio-logical effects of a loss-of power accident are included in Table 8.8 and 8.9.

8.8 References

1. Report on Safety Related Information for the Battelle Volume Reduction Demonstration Facility by Battelle Columbus Laboratories, Columbus, Ohio and ATCOR Engineered Systems Inc. Avon, Connecticut, August 15, 1983.

(Appendix G to Renewal Application BCL-1081).

2. Exxon Nuclear Company, Inc., Nuclear Fuel Recovery and Recycling Center Preliminary Safety Analysis Report, Docket 50-564, Appendix 9A.

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. 4 Table 8.8 Whole Body Dose to Maximally Exposed Individual from Loss-of-Power Accident Source Term: Reactor Material 36.9 cubic feet Activity Activity Dose Released X/Q Inhaled Factor Dose Nuclide mci sec/ma mci rem /50yrmCi rem /50yr Cr-51 9.63E-03 8.4E-05 2.81E-10 2.64E-01 7.41E-11 Mn-54 2.13E-02 8.4E-05 6.21E-10 6.30E00 3.91E-09 Co-58 1.99E-01 8.4E-05 5.80E-09 6.16E00 3.57E-08 Co-60 2.62E-01 8.4E-05 7.64E-09 1.50E02 1.15E-06 Sr-90 3.29E-04 8.4E-05 9.59E-12 1.30E03 1.25E-08 Zr-95 3.29E-03 8.4E-05 9.59E-11 1.85E01 1.77E-09 Ru-106 2.62E-03 8.4E-05 7.64E-11 4.40E02 3.36E-08 Sb-125 6.31E-04 8.4E-05 1.84E-11 9.25E00 1.70E-10 Cs-134** 4.43E00 8.4E-05 1,29E-07 4.80E01 6.20E-06 Cs-137** 1.14E01 8. 4E-05 3.32E-07 3.20E01 1.06E-05 H-3** 9.59E-01 8.4E-05 2.80E-08 6.17E-02 1.72E-09 C-14** 2.51E-02 8.4E-05 7.32E-10 2.31E-02 1.69E-11 Total Inhalation 1.80E-05

• Breathing Rate 3.47E-04 m3 /sec

• • 100% release Ground Depostion Activity Dose Release X/Q Desposition Factor Dose Nuclide mci sec/m3 pCi/m2 remm 2 /yrpCi rem /yr Co-60 2.62E-01 8.4E-05 2.20E02 1.04E-07 2.29E-05 8-12

. 4 Table 8.9 Whole Body Dose to Maximally Exposed Individual From Loss-of-Power Accident Source Term: Institutional Material 36.9 cubic feet Activity Activity

• Dose Released X/Q Inhaled Factor Dose Nuclide mci sec/m3 mci rem /50yrCi rem /50yr Co-60 9.63E-02 8.4E-05 2.81E-09 1.50E02 4.21E-07 Sr-90 1.36E-02 8. 4E-05 3.96E-10 1.30E03 5.15E-07 Cs-137** -4.80E00 8.4E-05 1.40E-07 3.20E01 4.47E-06 Tc-99 3.19E-08 8.4E-05 9.30E-16 8.33E00 7.75E-15 Am-241 4.64E-05 8.4E-05 1.36E-12 4.62E05 6.26E-07 H-3** 9.59E01 8.4E-05 2.80E-06 6.17E-02 1.72E-07 C-14** 5.54E00 8.4E-05 1.61E-07 2.31E-02 3.73E-09 I-125** 5.90E00 8.4E-05 1.72E-07 9.25E01 1.59E-05 Total Inhalation 2.21E-05

• Breathing rate 3.47E-04 m3/sec

• • 100% release Ground Deposition Activity Dose Release X/Q Deposition Factor Dose Nuclide mci sec/m3 pCi/m2 rem m2 /pCiyr rem /yr Co-60 9.63E-02 8.4E-05 8.09E01 1.04E-07 8.41E-06 8-13

m -_ _ _ _ . __ _ _ _ . _ _ _

o b 9.0 DISCUSSION OF WASTE MANAGEMENT OPTIONS The proposed VROF is designed to reduce the volume of radioactive materials disposed in LLW buria? facilities. As previously discussed, it is to be used as a demonstration facility and, as such, it may be inappropriate to compare the operation of the VROF with alternative processes. However, the following is presented for completeness of review. Alternatives to this process include 4

continuing present practices, volume reduction by material generator, volume reduction at-the disposal site, volume reduction by compaction, and selection

. of different volume reduction methods. These alternatives are discussed in the following sections. References are given in Section 9.7.

I ' 9.1 Continue Present Practices I

One possible alternative to the VRDF would be to continue present practices.

Individual waste generators would ship their waste to disposal sites, as they 4

do now, with limited volume reduction. The disposal of unreduced material

, would preclude releases of radioactive material to the atmosphere that would

. result from the volume reduction process. However, as shown in Sections 6 and j 8 of this document, the impacts of these releases would be small.

j In addition, the NRC's 1981 Policy Statement on LLW Volume Reduction states:

l "The NRC considers it desirable that licensees reduce the volume of' low-level

radioactive waste generated and shipped to commercial waste disposal sites.

i Such action would:

" 1. Extend the operational lifetime of the existing commercial low-level disposal sites; J

i "2. Alleviate concern for adequate storage capacity if there are delays in establishing additional regional sites; and l "3. Reduce the number of waste shipments."

i "NRC believes it is in the best interest of licensees and the public that licensees extensively explore means by which waste volume may be reduced."1 l Also, in January 1986, amendments to the 1980 Low-Level Radioactive Waste Policy l Act were enacted. One of the most important aspects of these amendments is the i

limit that is put on the amount of waste that can be disposed of in the rexisting

LLW disposal sites.

l. 9.2 Volume Reduction By Material Generator i .

As an alternative to a centralized volume reduction facility, waste generators

could perform their own volume reduction. Some generators now operate volume reduction processes. Most power reactor operators compact their material prior to shipment. However, they use only relatively low-force compaction. Indi-vidual generators, each producing relatively small volumes of material, probably could not economically justify the operation of a process using the more costly and effective technologies of the VROF.

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. b If generators did construct their own highly effective volume reduction facil-ities, the shipments from the generators to the VROF site would be eliminated.

Also, the environmental impact would be distributed, rather than located in one area. However, the environmental effects of waste transportation to the VROF and of operating the VROF are expected to be small (see Sections 6 and 8 of this report). Thus, the increased costs of this alternative would not be justified.

9.3 Volume Reduction at Existing Disposal Sites If volume reduction facilities were built at the existing disposal sites an increase in the number of shipments would be realized. Section 3.3.1 shows approximately fifteen times as many shipments of incoming unreduced material as outgoing reduced product from the VRDF. This potential gain must be re-duced by the additional travel required to use the VRDF. However, since the VROF is expected largely to be used by regional generators, the incremental distance increase would be relatively small.

The increase in truck-miles that would result if the unprocessed waste were shipped to the disposal sites for volume reduction is probably not significant for radiological impacts. The larger inventories on shipments of reduced material would offset the reduction in the number of shipments so that direct radiation doses to people along the routes would remain about the same. The quantity of radioactive material available for release in an accident would be higher for a shipment of reduced material than for a shipment of unreduced material. However, more truck miles could result in a greater chance of truck accidents. The magnitude of release of unreduced material would probably not be greatly different from that of reduced material, because the incinerator product would be nonflammable. ,

In addition to increasing the number of shipments, another disadvantage to locating volume reduction facilities at the existing disposal sites is that within several years these facilities will not be available to generators in some states. In December 1980, the Low-Level Radioactive Waste Policy Act (Public Law 96-573) was enacted. The Act states that each state is responsible for providing for the capacity either within or outside the state for the dis-posal of low-level radioactive waste generated within its borders. It also says that states may enter into compacts to provide for the establishment and operation of regional low-level radioactive waste disposal facilities. Amend-ments to the Act, in January 1986, continue access to current disposal facilities until January 1, 1993, after which time access to such facilities will end for states not within the currently-sited regions.

9.4 Build the VROF With a High-Force Compactor Only The VRDF could be built with a high-force compactor as the only method of volume reduction. If this were the case, the compactor could reduce the volume of some of the waste that could have been incinerated, such as much of the combus-tible trash. However, scintillation fluids and contaminated oils would not be compactible. Incineration is the most acceptable method for processing scintil-lation fluids because they present special problems in shallow land burial trenches due to the chemical mobility, chemical toxicity, and flammability of the organic solvents.2 9-2

In this alternative, the already small environmental impacts of the VRDF would be further lessened by about three orders of magnitude. The total volume reduc-tion available from compaction only would not be as great, however. The compactor would reduce the volume of combustibles probably by a factor of five, whereas the incinerator would reduce their volume by a factor of about thirty.

This loss of six times in volume reduction is significant compared with the small absolute reduction in environmental impacts.

9.5 Alternative Volume Reduction Methods The waste to be processed at the VRDF would consist of reactor trash and con-taminated oils; and industrial and institutional liquid scintillation vials containing scintillation fluid, other liquids, biological wastes, and trash.

Because of the variability of the composition of the waste to be processed at the VROF, the options available for volume reduction are limited to compaction and incineration. The options that do exist are limited to different designs for those processes.

There are other methods for treating liquid scintillation fluids, such as evaporation, distillation, and solidification. However, these treatments would not be viable for processing the other types of waste expected to be processed at the VRDF.

9.6 Evaluation of Alternatives None of the alternatives discussed above are clearly superior to the VRDF. The VRDF would provide maximum volume reduction at the least cost,while staying within Federal limits for radioactive emissions and radiation exposure to the workers and to the public.

9.7 References

1. Federal Register, Vol. 45, No. 200, " Policy Statement on Low-Level Waste '

Volume Reduction," October 16, 1981.

2. U.S. NRC, Draft Environmental Impact Statement on 10 CFR Part 61 " Licensing Requirements for Land Disposal of Radioactive Waste," Vol. 3, Appendix 0, NUREG-0782, September 1981.

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-10.0 SUMARY AND CONCLUSION OF ENVIRONMENTAL IMPACTS OF CONSTRUCTION AND OPERATIONS 10.1 Summary of the Environmental Effects of the VRDF The environmental effects of normal operation are expected to be very small.

For all nuclides, the maximum unrestricted area nuclide concentrations result-ing from normal operation are calculated to be below the maximum permissible concentrations specified in 10 CFR 20.106 and Appendix B. (See Table 6.3 of this report.)

10 CFR 20.105 effectively limits the whole body dose received by any individual in an unrestricted area to 0.5 rem per calendar year. In addition to the requirements set in 10 CFR 20, the EPA Clean Air Act Standard in 40 CFR 61 limits individual exposures to 25 millirem per year whole body dose and 75 millirem per year to the thyroid for members of the public. The normal opera-tions of the VROF would result in a dose to the maximum individual of 1.1 mrem per year whole body and 6.7 mrem per year thyroid. The maximally exposed person from normal transportation activities would receive an annual exposure of 0.082 mrem per year. Normal background radiation for the BCL area is about 135 mrom per year.

The dose received by the maximally exposed individual as a result of potential accidents would range from 0.00094 mrem f6r the container rupture to 1.0 mrem for waste storage area fire (see Table 8.1). There are no directly relevant numeric criteria for accident evaluation, however, the doses calculated are well below proposed EPA protective action guideline:.. Protective action guides are expressed in terms of projected doses to individuals in the population that warrant taking protective action. The EPA has published draft guides for taking protective action in order to avoid exposure to radiation as the result of an accident at a nuclear power plant. The EPA recommends that protective actions should be considered by responsible officials if projected whole body doses are in the range of 1 to 5 rees. The lower dose of 1 rem is~a level which "should be used if there are no major local constraints in providing protection at that level, expecially to sensitive populations" (children and pregnant women). The EPA telieves that "in no case should the higher value (5 rems) be exceeded in determining the need for protective action."

l 10.2 NRC Staff Findinas

! - Following are the NRC staff findings resulting from this Environmental l Assessment.

' 1. Construction and operation of the VRDF would be consistent with local land use patterns. It would be built within the 1000-acre tract of land owned by BCL, which is in an area that contains several small industrial /

institutional developments.

. 2. Construction and operation of the VROF would not cause significant dis-ruption on the plant and animal life of the area. Construction of the 10-1

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site undoubtedly caused some disruption in local ecological relationships and the loss of some wildlife habitat. However, these accomplished effects are considered minor. Since the VRDF would be constructed within the bounds of the BCL-owned property and adjacent to the Nuclear Sciences Area that contains several buildings, it is doubtful that it would cause any addi-tional disruption on the plant and animal life of the area.

3. The operation of the VROF would be consistent with the NRC policy state-ment 2 to reduce the amount of waste requiring disposal as much as possible.

4. The method to be used in the VRDF is an effective method for reducing the volume of LLW that is generated by nuclear power plants, institutions, and industries.

5. Calculations using the higher-than-expected quantities of waste show that the incinerator effluents would be less than 1 percent of the annual limit for concentrations (MPC) at the site boundaries. It is planned that stack samples would be taken at the VROF and analyzed periodically. Because i these samples are the only means of verifying stack emissions, the NRC staff will require that these samples be taken and analyzed daily.

6. Although a real-time monitor for accurate measurements of emissions to the atmosphere is not available, a real-time monitor could detect concen-trations of particulates exceeding the values in Appendix 8 of 10 CFR 20.

Installation of such a monitor will be required since there are no direct means of checking the radioactivity of the waste to be incinerated. The monitor would not detect concentrations of tritium, carbon-14 and iodine-125, however. .

7. Battelle did not address incinerator stack sampling systems to collect.

samples for measurement of iodine-125. The NRC staff will require that appropriate systems be used to measure tritium, carbon-14, and iodine-125 in the off gas.

8. The licensee must maintain administrative control procedures and records to demonstrate that the annual release limit of 10 mci of iodine-125 has not been exceeded.

9. The licensee will need to control area access in accordance with 10 CFR 20 by a suitable barrier.

10. BCL should test the HEPA installed filers after initial installation, at intervals not to exceed six months, and after filter change. Testing should comply with ANSI N101.1, " Efficiency Testing of Air-Cleaning Systems Con-taining Devices for Removal of Particles" using a " cold 00P" test with acceptance based on an efficiency of 99.95% or better.

11. BCL has proposed to take random samples of ash to be analyzed for alpha and beta gamma activity. The staff recommends that a determination o~f EP toxicity as set forth in 40 CFR 261.24, Table 1, is also appropriate; par-ticularly, in view of the intended purpose of the facility as a demonstra-tion of LLW management.

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12. BCL may need a Resource Conservation and Recovery Act (RCRA) permit in order to comply with 40 CFR 264.340 fo' incineration of hazardous waste.

13. BCL will develop experience in correlating and managing their receipt, processing and release data, and the NRL: will require that BCL submit a semiannual report of this experience.

14. BCL will need a Permit to install new sources of pollution issued by the Ohio EPA for operation of incinerator and will reapply for such a Permit.

15. On the basis of the information and results of analyses derived during the environmental assessment summarized above, the NRC staff finds that the environmental impact of construction and operations at the VRDF would be insignificant. Based on the above, a Finding of No Significant Impact is 4

warranted.

See attached page for additional staff findings.

10.3 References

1. EPA-520/1-75-001, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," Draft Revision of June, 1980.

i 2. Federal Register, Vol. 46, No. 200, " Policy Statement on Low-Level Waste Volume Reduction," October 16, 1981.

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@ Q APPENDIX A A .' OIOXIN AND ITS RELATIONSHIP TO INCINERATOR EMISSIONS A.1 INTRODUCTION This appendix briefly describes dioxin, its toxic effects, regulatory status, formation, methods of measurement, and the potential for dioxin formation during the operation of the VROF incinerator.

r A.2 DESCRIPTION OF DIOXIN Dioxin is a generic name for a class of compounds that can be formed as byproducts in certain chemical reactions and during many combustion / incineration processes.

The polychlorinated dioxins (PC00s) are the most common, of which, there are 75

, different isomers. The toxicity of dioxin to animal species is dependent on the number and placement of chlorine atoms on the dioxin molecule. The more toxic dioxins have four to six chlorine atoms with the 2,3,7, and 8 positions filled. The simplest of these is 2,3,7,8- tetrachlorodibenzo p-dioxin (TCDD).

Other molecules closely associated with the dioxins are the polychlorinated dibenzofurans (PCDFs).

Dioxin is stable to acids and alkali. At room temperature, TCOD is a colorless crystalline solid. It melts at 305*C. Dioxin's solubilit9 in water is very.

Iow (2E-4 ppm), but is slightly soluble in fats (44 ppm in lard oil). It is lipophilic, and it binds strongly to soils and other particulate matter.

'A.3 T0XICITY Dioxin is extremely toxic to certain animals, causes many different toxic effects in a wide range of animal species, and is harmful to humans when they are exposed to relatively large amounts of it. The long-term, irreversible health effects in humans remains unknown.

The claim that dioxin is one of the deadliest substances known is based on the extreme toxicity in guinea pigs. -As little as 0.6 up/kg body weight given orally j will kill half of the male guinea pigs that receive the dose. Illness occurs l immediately and death within about a week.

Dioxin (TC00) is much less toxic to mice than to guinea pigs. The guinea pig i- is 500 to 10,000 time more sensitive to TC00 than the hamster, which is the

! least sensitive anh'al tested. Rabbits, mice, and monkeys are roughly 200 times less sensitive than guinea pigs and 50 times more sensitive than hamsters. The l toxicity of dioxin in humans is expected to be about the same as that in monkeys.

! Considering this, TC00 is about ten times as toxic as hydrogen cyanide. Such j comparisons must be made with great care, since the ability of hydrogen cyanide to enter the body is many times greater than TCD0s.

! The known or suspected effects of exposures to TCD0 are: Chloracne (an erup-l tion of the skin causing blackheads, usually associated with small pale yellow j cysts); enlarged. liver and impairment of liver functions; and neurological i

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disturbances such as severe muscle pains aggravated by exertion, especially in the calves, thighs, and chest area; and sensorial impairments of sight, hearing, smell, and taste. Lassitude, weakness, impotence, and loss of libido have also been reported.

A.4 PERMISSIBLE CONCENTRATIONS OF DIOXIN In North America, both the Canadian government and the United States Environ-mental Protection Agency (US-EPA) have been actively studying the dioxin prob-lem but, as yet, have not promulgated any regulations limiting dioxin exposure in the environment. In Canada, however, the Ontario Ministry of Health has published a guideline of 30 pg/m3ambient for dioxins (TCDD).

In 1970, the Canadian government made the first regulation attempt by limiting the dioxin concentration in the herbicide 2,4,5-T (a common source of dioxin) to 500 parts per billion (ppb).

In 1979, dioxin was detected in fish in Lake Ontario at around six parts per trillion (ppt). A few years later, the Canadian government set a limit of twenty ppt as a virtually safe dose in fish used for human consumption.1 No regulatory requirements have been set in the United States. The US-EPA has used a decontami-nation criterion of one ppb for the work at Times Beach, Missouri. The United States Air Force is considering a limit of ten ppb for decommissioning of former agent orange storage sites.

All of the dioxin levels discussed above are based on the isomer 2,3,7,8-TCDD.

It is doubtful that more definitive levels will be established until the toxi-cological effects of 2,3,7,8-TCD0 are Better understood.

A.5 MECHANISMS FOR FORMATION OF DIOXIN DURING INCINERATION A. 5.1 General Mechanisms In many cases, the formation of dioxin involves a compound containing an ortho-substituted benzene ring and an oxygen atom attached directly to the ring. In addition, two substituents (but not the oxygen atom itself) must be able to react with each other to form another compound. The reaction is favored by temperatures in the range of 180 to 400 C. The presence of a catalyst, such as copper powder, promotes the reaction.

The three known major routes for dioxin formation are in the production of:

1. 2,4,5-trichlorophenol (TCP), the precursor to the several effective herbi-cides including 2,4,5-T, a major constituent in Agent Orange,

1. Pentachlorophenol (PCP), used in large tonnages to preserve wood, and

3. Polychlorinated biphenyls (PCBs), an excellent heat-transfer agent used in electrical transformers and capacitors.

Relative proportions of the various TCDD and TCDF isomers are dependent on their reaction rate, concentrations, and temperature control. These parameters are discussed further in the section related to incinerator generation of dioxins.

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In actuality there are many pathways by which trace amounts of chlorinated dibenzo p-dioxins can be formed. It is likely that whenever organic and chlorine-containing materials are burned together these pathways will be found.

This is discussed further in the following Section A.S.2.

A. S. 2. Mechanisms for Dioxin Formation During Incineration While not documented, it has been theorized that any combustion process (wood-stoves, forest fires, cigarettes, etc.) is capable of producing dioxins. This is expected to be true if any of the wood has been treated with polychlorinated phenols as a wood preservative.

In 1977, Olie, et al., reported the occurrence of dioxins and dibenzofurans in fly ash from three municipal incinerators in the Netherlands.2 The indicated the presence of approximately 17 different dioxin isomers, but were unable to quantify the isomers due to lack of standards.2 Buser and Bosshardt studied flyash from a municipal incinerator and an industrial heating facility, both in Switzerland. From the municipal incinerator, they found levels of 200 ppb total dioxin and 100 ppb total dibenzofuran, and from the industrial heating facility, 600 ppb and 300 ppb, respectively.3 Later studies have shown that the highly toxic 2,3,7,8-TCDD isomer can range from approximately 0.3 to 3% of the total dioxin content from combustion processes.4 Therefore, taking a worse case basis for the study in Switzerland, this would translate to approximately 6 ppb 2,3, 7,8-TCDD for the municipal incinerator and 18 ppb for the industrial heating facility.

Various mechanisms have been identified for the formation of PCDDs and poly-chlorinated dibenzofurans (PCDFs) during incineration processes (See References 2,4,6,7,8,9).

Several of these mechanisms for the formation of PCDDs and PCDFs during the incineration have been proposed by Lustenhouwer, Olie, and Hutzinger8 ,

including the following:

(a) In the incineration of refuse, PCDDs and PCDFs may be present as components .

of the fuel. Because of their thermal stabilities these compounds may not be destroyed during combustion but may instead volatilize and enter the process flue gas stream. This mechanism would be particularly significant for many refuse incinerators because they operate at combustion temperatures that are too low to destroy PCDDs and PCDFs.

(b) PCDDs and PCDFs may be formed due to thermally initiated reactions of mol-ecular species that are either present or are produced in the high temper-ature combustion zone. This type of in situ synthesis occurs via such

' reactions as rearrangements, free-radical condensation, dechlorination, dehydrogenation and/or other molecular reactions.

(c) If the combustion zone temperatures are high enough, PCDDs and PCDFs can be produced in situ by elementary recombination reactions of atoms produc-ed by the thermal combustion process.

It is expected that the formation of dioxins and furans via the mechanisms de-scribed in (b) and (c) above could occur in the VRSF incinerator. However, as discussed below, it is not expected that the concentration of dioxin released to the environment would be significant.

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A.5.3 Location of Formation of Dioxin There has been some question.about where the formation of dioxin would occur within the VROF and other incineration systems. Lustenhouwer, et al.,8 have reviewed the published reports that appear to support one or more of the mecha-nisms described _in Section A.5.2 of this report for the formation of dioxin.

In all cases reported, formation of PCDDs and PCDFs has been due to the elevated temperatures present in the combustion process. Therefore, the PCDDs and PCDFs would most likely be formed in the combustion chamber of the VRDF. However, as discussed in Section A.5.4 below, it is not expected that the dioxin potentially generated at the VRDF would be significant.

A.5.4 Variables Affecting Formation of Dioxin During Incineration-

-The radioactive contamination of the LLW would have no effect on the formation of dioxins during the incineration process at the VROF.

The feedstock and the efficiency of incineration are the operational variables that would affect the amounts of dioxins which are formed. The quantity of dioxin formed is more dependent on the efficiency of operation than on the feedstock.

A.S.4.1 Feedstock The type of materials being incinerated can somewhat influence the formation of dioxin. For example, the incineration of chlorinated phenols can produce minute quantities of chlorinated dioxins; PCBs can yield polychlorinated dibenzofurans

• and polychlorinated biphenylenes; while chlorinated benzenes can yield both polychlorinated dioxins and polychlorinated dibenzofurans. Polyvinyl chloride (PVC) can be a source of chlorine and on incomplete combustion yield minute quantities of chlorinated benzene which can be a precursor for both polychlori-nated dioxins and dibenzofurans.1 The VRDF would not process PCB-contaminated waste. It would, ho ver, inciner-ate benzenes (from liquid scintillation fluids) and limited quantities of PVC (5 percent by weight). It should be noted that municipal incinerators process l large quantities of PVC, and hazardous waste incinerators process both PC8s and i PVC. The expected feedstocks of the VRDF would produce no more, and probably

, less, polychlorinated dioxins and dibenzofurans than a municipal incinerator.

l This is due to the fact that the VRDF would have less variety of feedstock and

. more control over the materials being incinerated and the operating conditions of the incinerator.

A.5.4.2 Incinerator Operating Conditions The VRDF incinerator would be a two-stage combustion incinerator. The waste would be ignited and burned in the first stage (primary combustion chamber),

then the gaseous combustion products would pass to the second stage (secondary combustion chamber) where the oxidation process would be completed.

Whether dioxins would be emitted to the atmosphere as a result af operating the VRDF incinerator'would depend largely on the operating conditions of the sec-ondary combustion chamber. The parameters that would assure complete combus-tion (resulting in the destruction of dioxins) would be: high temperature, A-4

s 9 high oxygen concentration, and adequate residence time of the offgas in the secondary chamber. The VRDF secondary combustion chamber would operate at 950*C (1740 F), high excess air (about 100 percent), with an offgas residence time of 1.5 seconds at combustion chamber temperature in the duct between the combustion chamber and the hot gas filter.

According to Shaub, et al., this temperature and residence time would be adequate.

They calculated the temperatures required for efficient (99.99 percent) destruc-tion of dioxin at various residence times, as shown below.1'3 Residence Time Temperature required for 99.99% destruction 46.5 727 C 1341*F 1 second 977*C 1790 F 1/2 second 1000 C 1832*F 4 milliseconds 1227*C 2240 F 5 microseconds 1727 C 3141 F According to this reference, a 1-second residence time at a temperature of 977"C would destroy 99.99 percent of the dioxin. The VRDF combustion chamber duct, however, would operate at a slightly lower temperature (950*C) with a longer residence time (1.5 seconds). Therefore, according to this model, the VROF secondary combustion chamber and duct would destroy at least 99.99 percent of any dioxins that might have been formed during the combustion process In the first stage.

Also, a study by Wong2o showed that although dioxins can form at low tempera-ture combustion (below 800 C, 1472 F), they are effectively destroyed at high temperatures (above 900 C, 1652 F). The VRDF secondary combustion cham-ber would operate at a higher temperature, 950 C, and so according to this reference, would effectively destroy any dioxins that might have been formed during the combustion process in the first stage.

Another reference, Benfenati, et al.21, states that the emission of PC00 and PCDF from urban waste incineration is inversely related to the combustion tem-perature. They reported that this agrees with other authors who find that TC00 decomposes at temperatures higher than 800 C (1472*F), and that no PC00 can be measured in incinerators operated at high temperatures (greater than 1200*C, 2192 F). The VRDF secondary combustion chamber would operate at 950*C, well above the temperature at which TCOD decomposes. Considering this, along with the other references mentioned above, dioxin emissions from the VROF abould be not be a problem. -

Doyle, et al.,12 supports this conclusion. They find that, even using conserva-tive, worst-case modeling, the dioxin emissions from a newer, efficient, con-trolled air incinerator such as the VRDF's would not exceed the Ontario Ministry of Health's ambient guideline (30 pg/m3 PC00).

A.6 EMISSIONS CONTROL FOR DIOXIN AT THE VROF Some of the dioxin that could be formed at the VROF incinerator would be absorbed by the particulates in the off gas. Studies disagree on the fraction of dioxin which would be absorbed, however. A Canadian study showed that more dioxins A-5

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escape in off gas vapors than on the particulate and flyash, but another study 4 showed that most of the dioxins are absorbed by the flyash.

The dioxin which would be absorbed by particulates and flyash would be filtered by the VRDF incinerator's HEPA filter system, and hence would not escape to the environment. The dioxin contained in the vapor phase would not be effectively filtered; however, it is expected that the quantity of dioxins in the off gas would be negligible.

A.7 ANALYSIS METHODS For the past 15 years, a concentrated effort has been made to determine the presence of dioxins at lower and lower levels. In 1984, the Columbia National Fisheries Research Laboratory published an analytical method for the determina-tion of polychlorinated dioxins and dibenzofurans.5 This method is isomer-specific with a lower detection limit of approximately two ppt. The method is accurate to about +/- 25 percent, and uses a high resolution gas chromatograph coupled to a low resolution mass spectrometer.

BCL has no plans to monitor for dioxins at the VROF incinerator.

A.8 CONCLUSIONS The conclusions reached in this appendix result from an overall review of the available literature and are as follows:

(a) The levels of polychlorinated dioxins and dibenzofurans emitted to the atmosphere as a result of incineration are more dependent on the conditions of combustion than on the feedstock to the incinerator.

(b) The amount of polychlorinated dioxin and dibenzofuran formed during com-bustion will be roughly inversely proportional to the combustion efficiency.

(c) The efficiency of the VRDF incinerator (as reflected by the temperature, excess air, and off gas residence time in the VROF incineration process is adequate to allow efficient combustion of the dioxins and furans.

(d) The radioactive contamination of the LLW would have no effect on the formation of dioxins during the incineration process at the VROF.

(e) The expected VRDF feedstocks would result in the formation of no more, and probably less, polychlorinated dioxins and dibenzofurans than a municipal incinerator, since there would be less variety of feedstock and more con-trol over the materials being incinerated.

(f) There are no regulations controlling dioxin emissions. However, compared to municipal incinerators, operation of the VRDF incinerator should result in the formation and emission of less dioxin because of its uniform feed-stock and high efficiency. Doyle, et al.,12 supports this conclusion, finding that using conservative, worst-case modeling, the dioxin emissions from a newer, efficient, controlled air incinerator, such as the VRDF's, would not exceed the Ontario Ministry of Health 30 pg/m3 polychlorinated dioxin (PC00) ambient guideline.

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o J, v A.9 REFERENCES

1. Choudhary, G. , L.H. Keith, and C. Rappe, Chlorinated Dioxins and Dibenzofurans in the Total Environment, Butterworth Publishers, Woburn, MA, 1983.

2. Olie, K. P.L. Vermeulen, and 0. Hutzinger, "Chlorodibenzo p-dioxins and Dibenzofurakis as Trace Components of Fly Ash and Flue Gas of Some Municipal Incinerators in the Netherlands, Chemosphere, 6:455, 1977.

3. Buser, H. R. , H. P. 80sshardt, " Mitt. Geb. Lebensmittelunters," Hyg. , Vol.

69, pg. 191, 1978.

4. Rappe, C., " Analysis of Polychlorinated Dioxins and Furans," Environmental Science Technology, 18:78A, 1984.

5. Smith, L. M., D. L. Stalling, and J. L. Johnson, " Determination of Partper-

, Trillion levels of Polychlorinated Dibenzofurans and Dioxins in Environmental Samples," Analytical Chemistry,1984.

6. Buser, H. R., H. P. Bosshardt, C. Rappe, and R. Lindahl, " Identification of Polychlorinated Dibenzofuran Isomers in Fly Ash and PCB Pyrolysis,"

Chemosphere, 7:419, 1978. -

7. Bumb, R. R., W. B. Crummett, S. S. Cutie, J. R. Glendhill, R. H. Hummel, R. O. Kagel, L. L. Lamparski. E. V. Luona, D. L. Miller, T. J. Nestrick, L. A. Shadoff, R. A. Stehl, and J, S. Woods, " Trace Chemistries of Fire:

A Source of Chlorinated Dioxins," Science, 207:59, 1980.

8. Lustenhouwer, J. W. A. , K. Olie, and O. Hutzinger, "Clorinated Dibenzo-p-dioxins and Related Compounds in Incinerator Effluents," Chemosphere, 9:501, 1980.

9. Tie: nan, T. 0. , M. L. Taylor, J. G. Solch, G. F. VanNess , and J. H. Garrett, Resources Conservation, 9:343, 1982.

10. American Chemical Society, Abstracts of Papers, 189th ACS National Meeting, ISBN 8412-0904-9, April 28-May 3, 1985.

11. Cheremisinoff, Paul N., "Special Report on Air Toxic: Measuring and Monitoring," Pollution Engineering, June 1985.

12. Doyle, B.W., D.A. Drum and J.D..Lauber, "The Smoldering Question of Hospital Waste," Pollution Engineering, July 1985.

13. Fawcett, Howard H., Hazardous and Toxic Materials, Safe Handling and Disposal, John Wiley and Sons, 1984.

14. Hunt, Gary T. and Bruce A. Egan, " Air Toxics Update," Pollution Engineering, June 1985.

15. Klang, Yen-Hsiung and Amir A. Metry, Hazardous Waste Processing Technology, Ann Arbor Science, 1982.

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16. Long, Janice R. and David J. Hanson, " Dioxin Issue Focuses on Three Major Controversies in U.S." C&EN, June 6, 1983.

17. Rawis, Rebecca L. , " Dioxin's Human Toxicity Is Most Difficult Problem,"

C&EN, June 6, 1983.

18. Worthy, Ward, "Both Incidence, Control of Dioxin Are Highly Complex," C&EN, June 6, 1983.

19. Shaub, W. M., and Tsang, W., " Physical and Chemical Properties of Dioxins in Relation to Their Disposal," Chemical Kinetics Division Center for Chemical Physics, National BureaJ of Standards, Washington, DC.

20. Wong, T. S., " Dioxin Formation and Destruction in Combustion Processes,"

77th Annual Meeting of the Air Pollution Control Association, San Francisco, CA June 24-29, 1984.

21. Benfenati, E., et al., Polychlorinated Dibenzo p-dioxins (PCDD) and Poly-chlorinated Dibenzofurans (PCDF) in Emissions from an Urban Incinerator.

2. Correlation Between Concentration of Micropollutants and Combustion Conditions," Chemosphere, Volume 12, No. 9/10, pp 1151- 1156, 1983.

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