Text

Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002
	ML042640208
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	09/15/2004
From:	Hass K; Consumers Energy
To:	; Document Control Desk, NRC/FSME
References
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	Download: ML042640208 (101)
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consumers A CMS Energy Company Big Rock Point Nuclear Plant Kurt M. Haas 10269 US-31 North General Manager Charlevoix, Al/ 49720 10 CFR 20.2002 September 15, 2004 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

SUBJECT:

DOCKETS 50-155 AND 72-043 - LICENSE DPR BIG ROCK POINT PLANT

- REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES IN ACCORDANCE WITH 10 CFR 20.2002

References:

1. Letter from Big Rock Point to NRC dated March 14, 2001, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002

2. Letter from Big Rock Point to NRC dated May 18, 2001, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002

3. Letter from Big Rock Point to NRC dated June 20, 2001, Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002

4. Letter from NRC to Big Rock Point dated February 5, 2002, Proposed Disposal Procedures in Accordance with 10 CFR 20.2002 (TAC No. MB1463)

The purpose of this letter is to submit a revision to the above references and request NRC continued approval of proposed procedures for disposal of demolition debris in accordance with the provisions of 10 CFR 20.2002. Attachment Ito this letter contains a marked copy of the June 20, 2001 Request for Approval of Proposed Disposal Procedures Under 10 CFR 20.2002 Provisions (as approved in reference 4, above.) A vertical line in the right margin indicates proposed revisions. Attachment 2 is a copy of the proposed revisions without the marked, proposed revisions. Attachments 3, 4, and 5 are RESRAD assessments done to support the proposed revisions. The following items summarize the revisions included in this submittal:

1. This submittal revises the June 20, 2001 submittal in order to provide the latest available shipment parameters for demolition debris transported to the Michigan Type II landfill and for proposed shipment of PCB bulk product waste to the Environmental Quality Company (EQCo) landfill in Belleville, Michigan. Disposal of structural steel demolition debris, classified as PCB bulk product waste, does not fall within the bounds of the assumptions originally submitted in our referenced letters. The 10 CFR 20.2002 request stated that the demolition debris would be transferred to a State of Michigan licensed Type II landfill located approximately 60 miles from the Big Rock Point (BRP) Site. This letter justifies use of an alternate disposal site for PCB bulk product waste and requests an approval of the revision in accordance with 10 CFR 20.2002.

2. Big Rock Point now has more than a year of shipment experience on which to base more accurate shipment dose calculations. Calculations provided in the original submittal for dose to truck drivers utilized a conservatively high total quantity of shipped demolition debris by assuming a heavy shipment with a concentration of gamma I

emitters at 5.0 pCi/g, but a relatively low number of shipments. Lighter loads are being shipped than previously assumed, and shipments are now scheduled to occur over three years rather than one year as assumed in the original submittal. These factors serve to lower dose rates to the drivers, but increase the number of shipments required to reach the estimated total burial volume.

3. The total quantity of demolition debris for Michigan landfill disposal is estimated at 113 million pounds. This increase is due to a re-estimation of remaining quantities of waste, field experience, and non-impacted asphalt (15.5 million pounds) that has been added to the Big Rock Point site since decommissioning began, but was not included in the original submittal. Approximately 48.7 million pounds of demolition debris is considered to be potentially impacted.

4. Big Rock Point proposes to dispose of up to 3.05 million pounds of structural steel coated with PCB-contaminated paint, potentially including exterior steel from the containment building, classified by the EPA as PCB bulk product waste (40 CFR 761.3) at the EQCo Wayne Disposal Site #2 in Belleville, Michigan. Disposal of this PCB waste will be in accordance with the approved 10 CFR 20.2002 alternate disposal request dated February 5, 2002 and applicable Michigan disposal regulations. The EQCo site is located approximately 275 miles from Big Rock Point and is licensed as a PCB waste disposal facility by the State of Michigan and the U.S. Environmental Protection Agency.

Landfill design and institutional controls for this facility are equal or more restrictive than the requirements placed on a State of Michigan licensed Type II landfill.

Dose effects to waste truck drivers, landfill workers and future resident farmer from the revisions outlined are considered minor, are consistent with the original submittal and are well below the public dose objective of I mrem/year. Changes as a result of revised assumptions and dose calculations are included in the proposed request. It is important to note that no credit is taken for reduction in landfill worker or resident farmer doses associated with the disposal of demolition debris in Type II landfill for PCB wastes material sent to the EQCo facility. However, if the entire estimated quantity of PCB bulk product waste were sent to the EQCo facility, doses associated with disposal at the licensed Type II landfill would be reduced for these individuals.

NRC approval of this revision is requested by January 1, 2005.

Kurt M. Haas Site General Manager cc: Administrator, Region Ill, USNRC NRC Decommissioning Inspector - Big Rock Point NRC NMSS Project Manager Attachments 2

Attachment 1 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 Revision to the Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002 Submitted March 14, 2001, May 18, 2001, and June 20, 2001 Marked Copy - Proposed Revisions September 15, 2004 27 Pages

NUCLEAR REGULATORY COMMISSION 1 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS For the reasons hereinafter set forth, it is requested that approval be granted to the Consumers Energy Big Rock Point Plant (BRP), as licensed by Facility Operating License DPR-6, Docket 50-155, issued on May 1, 1964, for procedures controlling the disposal of demolition debris in accordance with provisions of 10 CFR 20.2002. A description of the waste material for disposal that potentially contains licensed materials, including the physical and chemical properties important to risk evaluation, and the proposed manner and conditions of waste disposal is provided in the following sections. The content of this application follows the guidance of NUREG-1 101, Volume 1, Onsite Disposal of Radioactive Waste - Guidance for Disposal by Subsurface Burial, March 1986 as applicable.

I. PROPOSED ACTIVITIES This request for approval of proposed disposal procedures in accordance with the provisions of 10 CFR 20.2002 allows Consumers Energy to dispose of demolition debris originating from decommissioning activities at BRP in a State of Michigan licensed Type II landfill or in a licensed PCB waste disposal facility where landfill design and institutional controls are equal to or more restrictive than the requirements placed on a State of Michigan licensed Type II landfill. The request is justified in the analysis discussed in the later sections of this document.

II. BACKGROUND By letters dated June 18, 1997, and June 26, 1997, Consumers Energy notified the NRC, pursuant to 10 CFR 50.82(a)(1)(i), that BRP would permanently cease operation on August 30,1997. On August 29, 1997, the reactor was permanently shutdown, ending 35 years of electric power generation. On September 22, 1997, another letter was forwarded to the NRC certifying that the fuel had been removed from the reactor vessel and placed in the spent fuel pool for storage.

The BRP site is located on the northeast shore of Lake Michigan in Charlevoix County in the northern part of Michigan's Lower Peninsula. The site is approximately 60 miles northeast of Traverse City, Michigan, and about 4 miles north of the small town of Charlevoix along US Route 31.

The reactor at the BRP was of relatively small size (75 MWe) and contained a significantly small radioactive source term, only about 10 percent that of a standard boiling water reactor (BWR). Consumers Energy's goal is to dismantle BRP in a safe, environmentally conscious, and cost effective manner. This action will result in the timely removal of the existing nuclear plant in accordance with the DECON option found acceptable to the NRC in its Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, NUREG-0586. Decommissioning activities started in June 1997, and are-is Attachment I Revision l12 September 15,2004

NUCLEAR REGULATORY COMMISSION 2 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS expected to be completed rinate-Tiin 2005-aft -whih its-Par 50 -ic-on-serllbe terminated.

As a part of the decommissioning process, Consumers Energy plans to dismantle the individual structures when they are empty and when they have been decontaminated and radiologically surveyed, as required. It is estimated that asotal-97.58415 million pounds of predominately concrete debris will originate from the decommissioning project!.

Approximately one half of this is non-impacted (i.e., has never had the potential for neutron activation or to be exposed to licensed radioactive materials). The other half has a potential to contain residual surface activity and/or neutron activation products in a limited quantity. This submission deals with the disposition of demolition debris from the BRP decommissioning. Big Rock Point proposes to dispose of up to 3.05 million pounds at an alternate disposal facility licensed to accept PCB waste. This waste stream consists of painted structural steel in which non-liquid PCBs are contained within the dried paint matrix and is classified as PCB bulk product waste.

III. JUSTIFICATION 10 CFR 20, Subpart K, §20.2001 requires that licensed radioactive material be disposed of only through (1) transfer to an authorized recipient, (2) decay in storage, (3) release in effluents within the limits in §20.1301, or (4) as authorized under §§20.2002, 20.2003, 20.2004, or §20.2005. This request for approval of proposed disposal procedures demonstrates compliance with 10 CFR 20.2001 requirements prior to disposal of demolition debris in a State of Michigan licensed landfill.

For demolition debris at BRP, three decommissioning options have been considered.

(1) License Termination with Structures Intact This option would involve removal of licensed radioactive materials from the existing structures to residual radioactivity levels acceptable for termination of the license. Verification of achieving these residual radioactivity levels would require conducting a final status survey (FSS) for license termination on the remaining structures as well as the site environs. Specific disadvantages for application of this option at BRP include a delay in our management's environmental stewardship goal and commitment for restoration of the site to greenfield status. This option would also result in an increased expenditure of ratepayer decommissioning funds necessary to perform a much expanded FSS

'An additional 15.5 millions pounds of non-impacted asphalt will also be disposed of in accordance with this submittal; this asphalt was installed after decommissioning began in 1997 and was not included in the original waste estimate. Revision 1-2 September 15,2004

NUCLEAR REGULATORY COMMISSION 3 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS and demobilization followed by remobilization of the construction work force necessary for ultimate removal of site structures.

(2) Demolition Followed by License Termination The initial process is similar to license termination with structures intact.

Removal of licensed radioactive materials from existing structures to residual radioactivity levels acceptable for license termination with unrestricted access would still be performed. However, prior to performing the FSS, the remaining structures would be demolished and the concrete rubble left on site.

The FSS would then be performed on the site environs. After license termination, the concrete rubble could be used as construction fill or disposed of in a State of Michigan licensed landfill facility. While this methodology appears to be able to meet all NRC requirements and public health and safety goals, the disadvantages are that the debris would be expensive to stabilize over the long-term context. Furthermore, redevelopment of the site after license termination for other uses may require that debris be removed at some later date and relocated to another location on-site or off-site.

This option could be performed with somewhat less expenditure of ratepayer decommissioning funds than Option (1).

(3) Demolition and Disposal Followed by License Termination This option involves removal of licensed radioactive materials from the existing structures and installations. After decontamination of a work area, debris would be disposed of in a State of Michigan licensed landfill facility.

After removal of all demolition debris, the FSS would then be performed on the site environs, the license terminated by the NRC and the site released for unrestricted future use. This option is the most cost-effective use of ratepayer decommissioning funds and will result in the most expedient environmental restoration of the site.

The option that is most attractive to Consumers Energy and the public stakeholders is the disposition of demolition debris in a landfill prior to license termination; therefore, BRP has selected Option (3) as the preferred option. The criterion used in the License Termination Rule (10 CFR 20, Subpart E) for termination of the site license for unrestricted use is a total effective dose equivalent (TEDE) of 25 mrem/year. In comparison, the TEDE of this submission-submittal for Option (3) (demolition debris disposal in a State of Michigan licensed landfill) is 1 mrem/year. Therefore, selection of Option (3) is protective of the public health and safety, is consistent with As Low as Reasonably Achievable (ALARA), as well as being most cost-effective. Revision A12 September 15, 2004

NUCLEAR REGULATORY COMMISSION 4 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Consumers Energy is committed to conducting and completing decommissioning in a safe and cost efficient manner consistent with all regulatory requirements. Furthermore, Consumers Energy has determined that it is in the best interest to restore the site to greenfield conditions. Given the location of the site on the shore of Lake Michigan, the land is a valuable resource to the company and to the citizens of the area. The demolition debris that will originate from the demolition and removal of structures at BRP is included in this submissionsubmittal. This demolition debris includes flooring materials, concrete, rebar, roofing materials, structural steel, the soils associated with digging up foundations and concrete and/or asphalt pavement or other similar solid materials.

While Options (1) and (2) can be conducted under 10 CFR 20, Subpart E, Consumers Energy believes that Option (3) should be conducted under Subpart K. Although Subpart E allows small quantities of detectable licensed material to be left onsite for license termination, until the license is terminated, no amount of licensed material may be released from the site unless it is authorized under Subpart K. Consumers Energy does not intend to make this submittal for intentional disposal of radioactive waste. However; it is recognized that a potential will exist for trace quantities of licensed material to be present in the demolition debris at levels below instrument detection capabilities. Therefore, this submittal is being made in accordance with provisions of 10 CFR 20.2002 because of the potential presence of licensed material in the demolition debris.

IV. DESCRIPTION OF WASTE A. Physical Properties The demolition debris that will originate from the demolition and removal of structures and paved surfaces at BRP includes flooring materials, concrete, rebar, roofing materials, structural steel, soils associated with digging up foundations and concrete and/or asphalt pavement or other similar solid materials.

The physical form of this demolition debris will be that of bulk material with various screen sizes ranging from particles the size of sand up to occasional monoliths with a volume of several cubic feet. For the purpose of analyses performed for this application, the demolition debris is assumed to be a homogenous mixture with a density of 4-50-94 pounds per cubic foot (2A1.5 g/cm 3).

The demolition debris will exist as a dry solid waste containing no absorbents or chelating agents.

B. Estimated Waste Volume and Burials Each Year It is estimated that the mass of both-entaminated-and-ion- ontaminatedpotentially impacted demolition debris originating from the decommissioning of BRP will total Revision -12 September 15, 2004

NUCLEAR REGULATORY COMMISSION 5 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS approximately 84$,48.7 -million pounds. With an assumed average demolition debrislandfill density of 4-50-94 pounds per cubic foot, the estimated volume of potentially impacted demolition debris for disposal at a State of Michigan licensed landfill will be approximately 63OO_518000 cubic feet. and 1.2 million cubic feet of combined impacted and non-impacted demolition debris. This represents approximately two-four percent of the annual volume of waste disposed at the landfill most likely to receive most BRP demolition debris.

For the purpose of analyses performed for this application, completion of landfill disposal of demolition debris is assumed to occur within a onethree-year period of time, with disposal of 50% of the total volume to occur in one year. BRP demolition debris will not be isolated or dedicated to a single burial cell at the landfill. Rather, it will be co-mingled with other landfill materials that are available for disposal when the demolition debris is delivered to the landfill facility.

Institutional controls required at a State of Michigan licensed landfill are discussed in a later section of this application. However, one of these requirements is that materials deposited in a burial cell are required to be covered with an interim 6-inch layer of soil each day. Final closure of the burial cell will not occur until the burial cell has reached its design capacity. Institutional controls for the licensed PCB landfill are pquaIpor more restrictive that those for a licensed MichiaganyppiJ landfill.

Therefore, if a burial for purposes of this application is defined as final closure of the burial cell in which BRP demolition debris has been deposited, the number of burials per year will be dependent on the total volume of other landfill materials delivered to the landfill for disposal. However, it should be noted that each day that demolition debris is deposited in a burial cell, it would be covered with an interim 6-inch layer of soil.

C. Radiological Characterization of Structural Concrete To date, over 200 core borings (2 inch diameter by 6 inch depth) have been taken from rooms or areas on the BRP site. Selection of the sampling location was biased toward areas expected to have the highest contamination potential. Each core has been analyzed onsite by gamma spectrometry and direct frisk to determine what types of radioactive material are present and how far the contaminants have penetrated into the concrete. The results of these onsite analyses are-were summarized in Enclosure 1 te-hisofBig Rock Point's submittal dated June 20, 2001.

In addition, portions of 14 core samples have been analyzed by an offsite laboratory (General Engineering Laboratories) at typical environmental monitoring lower limits of detection (LLD) using alpha and gamma Attachment I Revision 42 September 16, 2004

NUCLEAR REGULATORY COMMISSION 6 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS spectrometry as well as liquid scintillation to analyze for the presence of the following radionuclides:

Ac-227 Ac-228 Ag-108m Ag-110m Am-241 C-14 Cd-1 09 Ce-144 Cm-242 Cm-243/244 Co-60 Cs-134 Cs-135 Cs-137 Eu-152 Eu-154 Fe-55 H-3 I-129 K-40 Mn-54 Ni-59 Ni-63 Nb-94 Pb-214 Pm-147 Pu-241 Pu-238 Pu-239/240 Ru-106 Sb-125 Sr-90 Tc-99 U-233/234 U-235/236 U-238 Zn-65 One-half inch thick, near surface wafers from 12 of the core samples were submitted to represent potential radioactive materials remaining after remediation of the structural surfaces. Laboratory analysis of these samples identified only Co-60, Cs-137, Fe-55 and H-3 at levels greater than the LLD values. K-40, Pb-214, U-233/234 and U-238 were also detected in these samples but at levels that were indistinguishable from naturally occurring background levels measured in plant concrete samples that were not contaminated by licensed radioactive materials. The results of these samples with concentration values representing the average concentration in the one-half inch thick wafer are detailed in Table 1. Copies of the General Engineering Laboratories Certificate of Analysis for these samples are-were included as Enclosure 2 to this-Big Rock Point's submittal dated June 20,2001.

Attachment I Revision 42 September 15, 2004

NUCLEAR REGULATORY COMMISSION 7 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Table 1 Remediated Concrete Core Sample Results Radionuclide Sample Co-60 Cs-137 Fe-55 H-3 Number pCi/g pCi/g pCi/g pCi/g 19 <LLD <LLD <LLD <LLD 31 <LLD <LLD <LLD <LLD 83 <LLD 0.130 0.088 <LLD <LLD 104 <LLD 0.094 4 0.054 <LLD <LLD 112 0.084 +/- 0.065 <LLD <LLD 6.24 4 2.51 123 <LLD <LLD <LLD 9.47 4 2.88 128 <LLD 0.166 +/- 0.062 <LLD <LLD 7 <LLD <LLD <LLD <LLD 90 <LLD <LLD <LLD <LLD 149 0.458 4 0.114 <LLD <LLD <LLD 117 <LLD <LLD <LLD <LLD 100 <LLD <LLD <LLD <LLD 119* 2.47 4 0.739 <LLD <LLD <LLD 153* 0.292 +/- 0.140 0.282+0.128 <LLD <LLD

Remediated high surface contamination samples The final two core samples listed above were taken from areas having a high potential for surface contamination and are average values of subsurface samples taken at various concrete depths. Laboratory analysis of these samples identified only Co-60, Cs-137 and H-3. K-40, Pb-214, U-233/234 and U-238 were also detected in these samples but at levels that were indistinguishable from naturally occurring background levels measured in plant concrete samples that were not contaminated by licensed radioactive materials.

D. Calculated Licensed Radioactive Material Content of Demolition Debris Results of the radiological characterization of structural concrete and current remedial action contamination surveys were used to classify the surfaces as either uncontaminated, shallow surface contaminated or deep surface contaminated.

Uncontaminated surfaces were defined as surfaces having no detectable Revision 4-2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 8 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS contamination as evidenced by historical records review, current remedial action contamination surveys and laboratory analysis of representative core samples.

Shallow surface contamination is defined as surfaces having no detectable contamination (> 5,000 dpm/100 cm2 total activity) as evidenced by contamination surveys performed after remedial action (if required) but detectable shallow subsurface contamination identified by laboratory analysis of representative core samples. Shallow subsurface contamination is assumed (based on core sample profiling) to penetrate to a depth of 1 inch after surface remediation.

Deep surface contamination is defined as highly contaminated surfaces prior to remediation with no detectable contamination as evidenced by contamination surveys performed after remedial action, but with some detectable deep subsurface contamination identified by laboratory analysis of representative core samples. This subsurface contamination is assumed to penetrate to a depth of 6 inches after surface remediation.

Based on the results of the radiological characterization of structural concrete on a room-by-room basis, a total surface area of 10,200 square feet have been calculated to have deep surface contamination. 51,835 square feet have been calculated to have shallow surface contamination and the remainder is considered to be uncontaminated. This results in a calculated 5,100 cubic feet of deep surface contaminated concrete and 4,320 cubic feet of shallow surface contaminated concrete.

Averaging the greater than LLD results from Table 1 and applying the resulting concentrations to the 4,320 cubic feet of shallow surface contaminated concrete and 5,100 cubic feet of deep surface contaminated concrete results in concentrations and total activity as reported in Table 2. Revision 41-2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 9 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Table 2 Volumetric Contamination of Remediated Surface Contaminated Concrete Radionuclide Concentration (pCi/g) Total Activity (mCi)

Co-60 0.83 0.5320.613 Cs-137 0.17 04090.126 H-3 7.86 5.0425.806 Total 8.85 &6836.544 All 42-2548.65 million pounds of impacted concrete will be treated as potentially contaminated. The volumes of 4,320 cubic feet of shallow and 5,100 cubic feet of deep contamination as calculated from structural characterization analyses, will not be separated from impacted concrete debris. Therefore, as a conservative estimate of activity potentially present, activity concentrations from Table 2 were applied to the impacted demolition debris mass of 422548.65 million pounds resulting in total activity as reported in Table 3.

Table 3 Impacted Demolition Debris Total Activity (422.548.65 million pounds)

Radionuclide Concentration (pCi/g) Total Activity (mCi)

Co-60 0.83 4-618.4 Cs-137 0.17 -33.8 H-3 7.86 4-52175 Total 8.85 417197 E. Requested Limiting Demolition Debris Concentration To allow operational flexibility and ensure monitoring capability, Consumers Energy requests a bounding principal gamma emitter concentration limit of 5 pCi/gm for licensed radioactive materials contained as trace contamination in demolition debris for disposal in a State of Michigan licensed Type II landfill or alternate landfill licensed for disposal of PCB wastes. Adjusting the total activity reported in Table 3 to a bounding principal gamma emitter concentration limit of 5 pCi/gm results in the bounding activity reported in Table 4. Revision-12 September 15, 2004

NUCLEAR REGULATORY COMMISSION 10 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Table 4 Impacted Demolition Debris Bounding Activity (42.2548,.65 million pounds) l Radionuclide Concentration (pCi/g) Total Activity (mCi)

Co-60 4.15 98X92.1 I Cs-137 0.85 44619.0 l H-3 39.3 760875 l Total 44.3 986856 l To ensure that the 5 pCi/gm principal gamma emitter limit is not exceeded, structural surfaces *vill be surveyed prior to demolition to verify that surface contamination does not exceed 5,000 dpm/1 00 cm2 averaged over areas appropriate for the detection system utilized and all demolition debris will be monitored by a bulk assay system with an alarm setpoint established at or below the 5 pCi/gm principal gamma emitter limit prior to disposal.

Establishment of this bounding concentration limit will ensure that any uncertainties in the content of licensed radioactive material in demolition debris sent to a State of Michigan licensed landfill or alternate landfill licensed for disposal of PCB wastes will not present a dose impact problem.

F. Dose Impacts Dose impacts of the requested impacted demolition debris bounding activity were evaluated by performing calculations using the Table 4 radionuclide concentrations as source terms (reference Big Rock Point Engineering Analysis, EA-BRP-RAE-04-01, Disposal of Demolition Debris at Environmental Quality Company, Revision 0 and EA-BRP-RAE-04-02, Disposal of Demolition Debris at Environmental Quality Company: Alternative, Revision 0.) These calculations are bounding because release at a principal gamma emitter limit of 5 pCi/gm is assumed for all 42.2548.65 million pounds of impacted demolition debris. In practice, release surveys to a minimum detection limit of 5 pCi/gm of principal gamma emitters results in release of demolition debris from zero to 5 pCi/gm, or a mean of approximately 2.5 pCi/gm.

I. Transport Worker Dose Assessment An evaluation of transport worker dose was performed using MicroShield, Version 5.035.05, from Grove Engineering and site-specific assumptions Revision 42 September 15, 2004

NUCLEAR REGULATORY COMMISSION 11 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS %

including bounding concentration values presented in Table 4. The transport system chosen for this evaluation was a roll-off container system with dimensions of 21.5 feet long, 8 feet wide and 3.5 feet high.

In addition to the above, the following assumptions were also applied to the analysis. In each case, the driver's seat is assumed to be 1 foot away from the cabin wall, which is conservatively assumed to be 0.12 inches thick, made of iron. The material hauler part of the truck is assumed to be made of iron with 0.25-inch thick sides, floor and tailgates. The distance between the hauler part and the driver's cabin is assumed to be 4 feet.

a Transportationto a Licensed Type II Land ill:

It is assumed that three truck drivers will be used for the total duration of the project and that the number of loads transported will be divided equally between each driver. Given the anticipated volumes of the impacted demolition debris (10,000 cubic-yards), combined with the assumptions of standard load volumes in tandem trailers, transport of a1150% -of demolition debris within a one-year period and the driving time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per load to the landfill, each truck driver will be potentially exposed to radiation from residual radioactivity for 324 0O-hours.

Applying the above assumptions, results in a calculated dose rate to the driver of 9.87E-04 41.22E-03mrem/hour or an annual dose of O-366-0.320 mrem to each of the truck drivers.

b. Transportto a Licensed PCB Landfill:

Assume that two truck drivers will be used for transportation of PCB bulk product waste and that the number of loads transported will be divided equally between each driver. Given the maximum estimated 3.05 million pounds of PCB waste for disposal, combined with the assumptions of standard load volumes in tandem trailers, transport of all PCB waste within a one-year period and the driving time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months per load to the landfill, each truck driver will be potentially exposed to radiation from residual radioactivity for 180 hours0.00208 days 0.05 hours 2.97619e-4 weeks 6.849e-5 months . Applying the above assumptions, results in a calculated dose rate to the driver of 9.87E-04 mrem/hour or an annual dose of 0.178 mrem to each of the truck drivers.

Output from the MicroShield analysis is provided as Enclosure-Attachment 3 to this submittal-ande-n-lectronio-file-(ROslffmSSROLL-4MSS-and Q45R-ofthe-analysis4s-inoluded-on-the-nclosed-computer-compact disk.

Attachment I Revision 42 September 15, 2004

NUCLEAR REGULATORY COMMISSION 12 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

2. Landfill Worker Dose Assessment An evaluation of landfill worker dose was performed using RESRAD, Version 6.0. For landfill operation, the landfill is assumed to close after placement of the demolition debris. Post-closure monitoring of the landfill is required by the State of Michigan for a 30-year period. Therefore, it is assumed that a member of the public, other than a landfill worker will not have access to a burial cell containing the demolition debris until 30 years after debris placement.

The following assumptions were made in the evaluation:

a. The most exposed individual at the landfill is a bulldozer operator, positioning and spreading the demolition debris and placing a soil cap on it at the end of the day.

b. The landfill most likely to receive BRP demolition debris currently has three bulldozer operators and, for purposes of this assessment, dose was assumed to be equally distributed between each bulldozer operator.

c. The 281,5 00522 200 cubic feet (7493 1471 0 cubic meters) of impacted demolition debris are assumed to be deposited in a uniform 23.71-meter thick, 3,965 square meter (0.98 acre) layer, assuming all demolition debris is buried in the licensed Type II landfill.

d. Based on the 0.98 acre surface area estimate of impacted demolition debris and a burial cell surface area of 8 acres, each landfill worker is assumed to spend 12.25 percent (0.98 acre/8 acres) of each worker's time working over or exposed to impacted demolition debris or 245 hours0.00284 days 0.0681 hours 4.050926e-4 weeks 9.32225e-5 months per occupational year of 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months . This total of 245 hours0.00284 days 0.0681 hours 4.050926e-4 weeks 9.32225e-5 months equates to a RESRAD outdoor time fraction of 0.028.

e. A 0.15 m soil cover (which is a daily cover requirement) was assumed.

No credit was taken for any other engineering controls required by the State of Michigan.

f. No credit was taken for shielding provided to the workers by the bulldozer. Revision 42 September 15, 2004

NUCLEAR REGULATORY COMMISSION 13 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

g. The bounding concentration values presented in Table 4 were used as the impacted demolition debris source terms.

h. Doses will be distributed to workers at each landfill in proportion to the total quantity of radioactive material potentially present. Conservatively assuming a constant maximum level of 5.0 pCi/g, doses are proportionate to the weights shipped to each site.

Use of the above assumptions results in a calculated annual TEDE dose of 0.190-0.291 mrem for each Type II landfill worker and a weight-proportionate dose of 0.01 82 mrem for the PCB landfill worker. Output from the RESRAD analysis is provided as Enclosure-Attachment 4 to this submittal-and-an e~ectronic4}e#orer -the-anayisin cudedn-h"-no10sed computer-wmpatdisk.

3. Landfill Resident / Farmer Dose Assessment An evaluation of dose to an individual member of the public was performed using RESRAD, Version 6.0. Post-closure monitoring of the landfill is required by the State of Michigan for a 30-year period. For purposes of this evaluation, it is assumed that a residence, including a basement to the residence and a vegetable garden, is established on the burial cell containing the demolition debris 30 years after debris disposal.

The following assumptions were made in the evaluation:

a. All RESRAD exposure pathways are active for the Resident / Farmer scenario except for the radon pathway (not regulated by the NRC).

b. The impacted demolition debris is assumed to be soil like material with the bounding concentration values presented in Table 4 even though its density is somewhat higher than most soils. Additionally, resuspension of demolition debris radioactivity is not expected to vary significantly from that for soil. Therefore, the RESRAD default soil parameters are considered appropriate for use in this analysis.

c. It is assumed that all licensed radioactive material in the impacted demolition debris is dispersed throughout the volume of impacted material originating at BRP and no dilution of the demolition debris occurs from other landfill materials deposited in the burial cell. This is very conservative since Michigan law requires a 6-inch soil cover over the debris at the end of each day and the demolition debris is expected to Revision -12 September 15, 2004

NUCLEAR REGULATORY COMMISSION 14 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS be only two percent of the total waste volume processed at the landfill over a one-year period.

d. For the Resident / Farmer scenario, it is assumed that the resident spends 50 percent of the time indoors, 25 percent outdoors at the site, and 25 percent of the time away from the site. These assumptions are consistent with those suggested in the NRC Policy and Guidance Directive PG-8-08, Scenarios for Assessing Potential Doses Associated with Residual Radioactivity.

e. Fifty percent effectiveness is assumed for the leachate collection system required by the State of Michigan (resulting in a 50 percent reduction in calculated annual dose). Also, the required 18-inch infiltration layer, 24-inch erosion layer and 6-inch earthen material layer capable of sustaining native plant growth are considered to be intact at the end of the 30-year period.

f. No credit is taken for landfill material originating elsewhere which may be deposited on top of the demolition debris.

g. The 522,20084.3500 cubic feet (14,7107-9M cubic meters) of impacted demolition debris are assumed to be deposited in a uniform 23.71-meter thick, 3,965 square meter (0.98 acre) layer, assuming all demolition debris is buried in the licensed Type II landfill.

h. For the RESRAD model, root depth was extended from the default value of 0.9 m to a depth of 1.4 m. This was done to ensure communication between vegetation and the contaminated zone.

i. All other RESRAD parameters were set at their default values for this evaluation. An Engineering Analysis was performed on RESRAD parameter selections and concluded that, when applied to the northern Michigan climate and State of Michigan licensed Type II landfill requirements discussed in Section VIII, the use of default parameters will result in conservative dose estimates.

j. Doses will be distributed to residents at each landfill in proportion to the total quantity of radioactive material potentially present. Conservatively assuming a constant maximum level of 5.0 pCi/g, doses are proportionate to the weights buried at each site.

Attachment I Revision -12 September 15, 2004

NUCLEAR REGULATORY COMMISSION 15 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Applying the above assumptions results in a calculated maximum annual dose of 0.009178 mrem for a resident / farmer living at the Type II landfill site.

This maximum annual dose occurs the first year of public access following the 30-year post-closure monitoring period. Using the assumption of weight proportionality, resident farmer living at the PCB landfill site would receive an annual dose of 0.001 mrem. Output from the RESRAD analysis is provided as Enelesure-Attachment 5 to this submittal-and-ani-le-trrnk-flle-(-ublraod)-of theanalysis-inudedonthe-enolesed-compute-r-ompao-isk.

4. Dose Impact Conclusions Assuming that all impacted demolition debris would be released for State of Michigan licensed Type II landfill disposal at a bounding principal gamma emitter concentration limit of 5 pCi/gm as trace contamination in demolition debris would result in a maximum dose impact to an individual member of the public of 0.3660.320 mrem/year to each of three transport workers. Maximum dose to each landfill worker was calculated to be 0.2901 mrem/year during impacted demolition debris disposal. Maximum calculated dose to a resident /

farmer was calculated to be 0.00918 mrem/year which would not occur until after completion of the required 30-year post-closure monitoring period. These maximum calculated doses are well below the public dose objective of 1 mrem/year. Annual doses associated with disposal of demolition debris classified as PCB bulk product waste at a licensed PCB waste facility with design and institutional controls equal or greater that the a Type II landfill are 0.178 mrem to each of the truck drivers, 0.018 mrem to a landfill worker and 0.001 mrem to a resident farmer. If the entire estimated quantity of PCB bulk product waste were sent to the alternate disposal facility, doses associated with disposal at the licensed Type II landfill would be reduced by the quantities above. However, only truck driver doses have been credited with reduced dose in this analysis.

Actual maximum dose impact to an individual member of the public is expected to be much less than these calculated values using a bounding principal gamma emitter concentration limit of 5 pCi/gm.

To ensure that the 5 pCi/gm principal gamma emitter limit is not exceeded, structural surfaces will be surveyed prior to demolition to verify that surface contamination does not exceed 5,000 dpm/l00 cm2 averaged over areas appropriate for the detection system utilized and all demolition debris will be monitored by a bulk assay system with an alarm setpoint established at or below the 5 pCi/gm principal gamma emitter limit prior to disposal. Revision 4-2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 16 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS G. Prohibition on Burial of Hazardous Waste Hazardous waste as defined in the regulations of the Environmental Protection Agency (EPA), 40 CFR Parts 260 through 265, is not permitted to be included in the BRP demolition debris. Hazardous waste is required to be disposed of in a manner set out in EPA regulations and in accordance with applicable local and State laws and codes, and will not be disposed of in conjunction with the debris considered here.

V. PACKAGING OF WASTE Big Rock Point demolition debris to be disposed of at a State of Michigan licensed Type II landfill or a licensed PCB landfill will not be packaged. Since the radiological survey process used to determine that the demolition debris is acceptable for landfill disposal will ensure that trace quantities of licensed material potentially present in the demolition debris are at levels below the requested bounding concentration limit, BRP demolition debris will be processed the same as debris generated from the demolition of any non-nuclear industrial facility.

The existing Radiation Protection Program, which is continually audited by the NRC, will ensure the radiological safety of BRP workers during generation and packaging of demolition debris. The dose evaluations discussed previously demonstrate that dose to members of the public from transportation and disposal of demolitions debris would not be measurable with state-of-the-art personnel monitoring instrumentation and is insignificant in comparison to the average annual dose received by individuals from natural sources (approximately 300 mrem per year).

Demolition debris will be transported from the BRP site to the landfill facility by truck transportation using either of three types of truck transport systems that are generally the common practice for carrying demolition debris. These transport systems include a roll-off container system, a dual-trailer mule system or a wide-bodied demolition hauler.

Roll-off container systems have the dimensions of 21.5 feet long by 8 feet wide by 3.5 feet high. Dual-trailer mule systems use two trailers, each having the dimensions of 50 feet long by 8 feet wide by 5 feet high. Wide-bodied demolition haulers have the dimensions of 30 feet long by 8 feet wide by 6 feet high.

Type II landfills licensed by the State of Michigan and PCB landfills licensed by the State of Michigan and the U.S. Environmental Protection Agency are required to implement controls to isolate the contents of burial cells from the environment. These controls will provide isolation of the BRP demolition debris from the environment over a reasonable period of time similar to the use waste packaging. The controls are discussed in Section VIII, Nature of the Burial Site.

Attachment I Revision 4-2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 17 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS VI. BURIAL LOCATION The State of Michigan licensed Type II landfill selected for burial of BRP demolition debris will be located within approximately 60 miles of the BRP site. The facility selected for disposal of PCB bulk products wastes is located approximately 275 miles from the BRP site.

The State of Michigan Solid Waste Management Act Administrative Rules Promulgated Pursuant To Part 115 Of the Natural Resources and Environmental Protection Act, 1994 Pa 451, As Amended contains restrictions on the location of Type II landfill facilities.

Among these are restrictions on groundwater isolation, horizontal isolation distances, floodplains, wetlands, fault areas and seismic impact zones, and unstable areas. These restrictions are discussed in Section VIII, Nature of the Burial Site.

VII. INSTITUTIONAL CONTROLS Part 1 5 of the State of Michigan Administrative Rules contains institutional controls that restrict access to Type II licensed landfills. Licensing requirements for the landfill selected for disposal of PCB bulk products wastes are considered equal or more restrictive than those for licensed Type II landfills. The landfill operator is required to control public access to the landfill and prevent unauthorized vehicular traffic and illegal dumping of wastes by using artificial or natural barriers, or both, as appropriate.

After the final closure of a burial cell, the landfill operator is required to conduct post-closure care for not less than 30 years. This post-closure care includes:

Maintaining the integrity and effectiveness of any final cover,

Maintaining, operating, and monitoring the leachate collection system,

Monitoring the groundwater,

Monitoring all secondary collection systems and leak detection systems, and

Maintaining and operating the gas monitoring and collection system.

VIII. NATURE OF THE BURIAL SITE The Type II landfill where the BRP demolition debris will be sent for disposal will meet State of Michigan Part 115 Administrative Rules that will limit migration of licensed radioactive material potentially mixed with the demolition debris in trace amounts. These requirements include but are not limited to:

Location restrictions,

A composite liner,

Leachate collection and removal systems, Revision 4_2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 18 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

Leak detection systems,

Daily 6 inch interim soil covers,

Explosive gas control and monitoring,

Groundwater monitoring,

Surface and Groundwater Performance,

Run-On and Run-Off Control Systems, and

Final cover composite liner designed to minimize infiltration and erosion.

A. Location Restrictions The location of each burial cell will be isolated from groundwater sources.

Permanent minimum clearances of ten feet to the natural groundwater level and 7 feet to a permanently depressed groundwater level is required to be maintained from the top of the primary liner.

The active work area at the landfill is required to not be located closer than 100 feet to adjacent property lines or road rights-of-way or closer than 300 feet to domiciles that exist at the time a landfill license is requested. It is also not allowed to be located within 400 feet of inland lakes and streams or within 2,000 feet of the Great Lakes. The active work area is also required to be a minimum of 2,000 feet from wells that serve Type I and Type Ila water supplies and a minimum distance of 800 feet from wells that serve Type IIb and Type III public water supplies.

If a landfill is located within a floodplain, the landfill operator is required to demonstrate that:

The cell will not restrict the flow of the 100-year flood,

The cell will not reduce the temporary water storage capacity of the floodplain,

The cell will not result in washout of solid waste so as to pose a hazard to human health and the environment,

The cell does not encroach upon the floodway and will not increase upstream or downstream flood stages,

The cell has a natural or compacted soil base which is not less than 10 feet thick,

The distance from the normal water line of the water body to the solid waste boundary of the landfill will not be less than 500 feet, and Attachment I Revision 4_2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 19 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS The design of the landfill will include a dike to preclude floodwater inundation with a top elevation that is not less than 5 feet above the 100-year flood elevation.

Landfills are not allowed to be located in wetlands unless extensive measures are taken for protection of the wetlands.

Landfill burial cells are not permitted to be located within 200 feet of a fault that has had displacement in holocene time, unless the landfill operator demonstrates that an alternative setback distance of less than 200 feet will prevent damage to the structural integrity of the cell and will be protective of human health and the environment. They are also not permitted to be located in seismic impact zones, unless the landfill operator demonstrates that all containment structures, including liners, leachate collection systems, and surface water control systems, are designed to resist the maximum horizontal acceleration in lithified earth material for the site.

B. Composite Liners Burial cells are required to be constructed with a composite liner and a leachate collection system that is designed and constructed to maintain less than a 1-foot depth of leachate over the liner, excluding the sump.

Burial cells are required to be located, designed, and constructed so that the risks posed by leakage through the composite liner are minimized. To do so, a cell is required to be either a monitorable cell that is located over a natural soil barrier so as to restrict the migration of leakage from the unit or designed with a double liner system that is capable of detecting and collecting leakage through the primary composite liner.

C. Leachate Collection and Removal Systems Each burial cell is required to have a leachate collection system that is designed and constructed to maintain less than a 1-foot depth of leachate over the primary liner.

To do so, the system is required to be designed to do all of the following:

Limit the head at any point in the system, excluding the sump, to not more than 1 foot,

Extend across the entire bottom of the system,

Be chemically resistant to the waste that is managed in the landfill and the leachate that is expected to be generated and be of sufficient strength and Revision l2j September 15, 2004

NUCLEAR REGULATORY COMMISSION 20 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS thickness to prevent collapse under the pressures that are exerted by overlying wastes, waste cover materials, and equipment that is used at the landfill,

Minimize clogging during the active life and postclosure care period,

Drain leachate to sumps using pumps that are of a sufficient size to collect and remove liquids from the sump and prevent liquids from backing up into the drainage layer. The design of each sump and removal system provides a method for measuring and recording the volume of liquids removed and the depth of leachate in the sump.

A secondary collection system is required to be provided and be capable of detecting, collecting, and removing leaks of hazardous constituents at the earliest practicable time through all areas of the top liner that are likely to be exposed to waste or leachate during the active life and postclosure care period.

The landfill operator is required to remove leachate from a burial cell as frequently as necessary to ensure that the leachate depth on the liner, excluding the sump, is not more than 1 foot, except after a significant storm event. The leachate depth on the liner is not allowed to be more than 1 foot for more than seven days after a significant storm event. A significant storm event is a storm that generates 0.1 inches or more of rainfall in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

D. Leak Detection Systems Each burial cell is required to have a leak detection system. For unmonitorable units, the secondary collection system is also a leak detection system. A response flow rate is established in the operating license for each landfill to evaluate the performance of a leak detection system.

If the average daily flow rate removed from the sump of a leak detection system is more than the action flow rate for that burial cell, the landfill operator is required to evaluate the chemical characteristics of liquid in the leak detection system by sampling and analyzing the system and evaluating for the presence of a leak by a statistical test, a trend analysis, or other means. Before solid waste is placed in any new burial cell that has a leak detection system, the landfill operator may, at his discretion, establish a baseline concentration of constituents in the secondary collection system based on an analysis of representative samples from the system.

The landfill operator must conduct required response actions if monitoring of the leak detection system determines that both of the following apply to liquid that is removed from the system: Revision 4-2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 21 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

The average daily flow rate is more than the response flow rate that is established for the unit and

The liquid contains hazardous substances indicative of leachate from the unit.

A landfill operator who is required to conduct response actions is required to take all of the following actions:

Within seven days of a determination that the response flow rate has been exceeded, notify the State of Michigan, in writing, that the response flow rate has been exceeded,

Submit a preliminary written assessment to the State of Michigan within 14 days of a determination that the response flow rate has been exceeded. A preliminary written assessment is required to include all of the following information for the landfill cell in which the response flow rate was exceeded:

o The amount of liquids removed from the leak detection system, o The likely sources of liquids, including the depth of leachate in the leachate collection system, o The possible location, size, and cause of any leaks, and o The short-term actions taken and planned.

Determine, to the extent practicable, the location, size, and cause of any leak.

Determine whether waste receipt should cease or be curtailed, whether any waste should be removed from the landfill cell for inspection, repairs, or controls, and whether or not the cell should be closed.

Determine any other short-term and longer-term actions to be taken to mitigate or stop any leaks.

After a determination that the response flow rate has been exceeded, and for as long as the flow rate in the system exceeds the response flow rate, the landfill operator is required to submit to the State of Michigan, within 30 days of the end of the calendar quarter, a report that summarizes the results of any remedial actions taken and planned.

To make the leak or remediation determinations required, the landfill operator is required to do all of the following: Revision 42 September 15, 2004

NUCLEAR REGULATORY COMMISSION 22 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS o Assess the source of liquids and amounts of liquids by source, o Conduct a fingerprint, hazardous constituent, or other analysis of the liquids in the system to identify the source of liquids and possible location of any leaks and the hazard and mobility of the liquid, and o Assess the seriousness of any leaks in terms of potential for escaping into the environment or document why the assessments are not needed.

E. Daily Six-Inch Soil Covers The landfill operator is required to cover disposed of solid waste with 6 inches of earthen material at the end of each operating day or at more frequent intervals, if necessary, to control disease vectors, fires, odors, blowing litter, and scavenging. If clay or other low-permeability material is used as daily cover, then the operator is required to scrape back the previous day's cover to allow the free movement of liquids and gases through the landfill.

If an active burial cell will lie idle for a period of three months or more before additional lifts are constructed, the landfill operator is required to place 1 foot of compacted cover, which may include the 6-inch daily cover, on the surface to minimize nuisance conditions.

F. Explosive Gas Control and Monitoring The landfill operator is required to ensure that the concentration of methane gas generated by the facility is not more than 25 percent of the lower explosive limit for methane in facility structures, excluding gas control or recovery system components, and the leachate collection system and that the concentration of methane gas is not more than the lower explosive limit at or beyond the facility property boundary. To demonstrate compliance with this requirement the landfill operator is required to implement a routine methane monitoring program.

G. Groundwater Monitoring Detection monitoring is required at all required groundwater monitoring wells. At a minimum, a detection-monitoring program for a landfill is required to include monitoring for all of the following constituents:

The listed primary indicators and pH, at least quarterly during the active life and semiannually during the postclosure period and Revision 4_2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 23 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS The following constituents listed at least semiannually during the active life of the facility and the postclosure period:

o Heavy metals that are listed, o Listed primary volatile organic constituents, and o Listed secondary organic constituents.

The landfill operator of a cell that contains a secondary collection system may conduct sampling and analysis for listed primary indicators in place of the heavy metals if all of the following conditions are met:

Leachate monitoring shows that the concentration of all of the indicators in leachate is not less than ten times the concentration in groundwater and

Secondary collection system monitoring shows all of the following:

o That the allowable flow rate has not been exceeded, o That the concentration of two or more indicators in the system is not more than the following threshold values for two consecutive sampling events:

For chlorides, 250 mg/I,

For iron, 0.3 mg/I,

For sulfates, 250 mg/I,

For total inorganic nitrogen, 10 mg/I, and

For total dissolved solids, 500 mg/I.

o That listed volatile organics have not been detected in the secondary collection system, o That the listed concentration of metals has not exceeded 1/10 the specified value,

The unit is a monitorable unit, and

The concentration of the indicators in groundwater is normally distributed.

Assessment monitoring is required at a landfill if a statistically significant increase over background has been detected for one or more of the listed constituents.

Within 90 days of the triggering of an assessment monitoring program, and annually thereafter, the landfill operator is required to sample and analyze the groundwater for all constituents listed in 40 CFR part 258, Appendix II. A minimum of one sample Revision 42 September 15, 2004

NUCLEAR REGULATORY COMMISSION 24 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS from each downgradient well is required to be collected and analyzed during each sampling event. For any constituent that is detected in the downgradient wells as a result of the complete Appendix II constituent analysis, a minimum of four independent samples from each background and downgradient well are required to be collected and analyzed to establish background for the constituents.

H. Surface and Groundwater Performance Operation of a State of Michigan licensed landfill is not allowed to cause a discharge of pollutants into waters of the United States, including wetlands, that is in violation of any of the requirements of the federal clean water act, including the national pollutant discharge elimination system (NPDES) requirements under Section 402 of the Federal Clean Water Act. Also, the landfill is not allowed to cause the discharge of a nonpoint source of pollution to waters of the United States, including wetlands, that is in violation of any of the requirements of an areawide or statewide water quality management plan that has been approved under Section 208 or 319 of the Federal Clean Water Act.

To demonstrate compliance with these requirements, the landfill operator is required to conduct a surface water-monitoring program approved by the State of Michigan for any surface water that may receive run-off from the active work area.

Monitoring results are required to be submitted to the State of Michigan not more than 30 days after the end of the calendar quarter.

I. Run-On and Run-Off Control Systems Two systems are required to control the flow of rainwater over burial cells. A run-on control system is required to prevent flow onto the active portion of the landfill during the peak discharge from a 25-year, 24-hour storm. Also, a run-off control system from the active portion of the landfill is required to collect and control at least the water volume that results from a 24-hour, 25-year storm.

J. Final Cover Composite Liner A final cover system is required to be installed on each burial cell which is designed to minimize infiltration and erosion and which is comprised of an erosion layer underlain by an infiltration layer. The final cover system is required to be comprised of the following components:

An infiltration layer that is comprised of either a minimum of 18 inches of earthen material that has a permeability which is less than or equal to 1.0 x 10-5 cm/sec or a bentonite geocomposite liner which is underlain by not less than Revision 42 September 15, 2004

NUCLEAR REGULATORY COMMISSION 25 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS 18 inches of earthen material to protect the liner from waste and minimize the effect of settlement.

An erosion layer that consists of both a soil layer which is not less than 2 feet thick, which is immediately above the composite cover liner, and which is designed to do all of the following:

o Provide for the lateral drainage of precipitation off the cover of the landfill, o Minimize frost penetration into the infiltration layer, and o Protect the flexible membrane liner from root penetration, ultraviolet light, and other deleterious effects.

A minimum of 6 inches of earthen material capable of sustaining native plant growth is required to be placed over the final cover system. To prevent the ponding of water on completed fill surfaces, the grading contours are required to be sufficient to prevent the development of local depressions due to post construction settlement.

Slopes of the final cover are required to be not less than four percent at any location.

IX. BURIAL PROCEDURES Please refer to Section VIII, Nature of the Burial Site regarding the burial of BRP demolition debris at a-State of Michigan licensed landfill facilitisy.

X. RADIATION SAFETY PROCEDURES BRP is currently conducting decommissioning activities under a Radiation Protection Program and implementing procedures that comply with NRC regulatory requirements contained in 10 CFR 20, Standards for Protection Against Radiation. The Radiation Protection Program and implementing procedures are a requirement of the BRP Defueled Technical Specifications 6.6.1 and 6.6.2. The NRC Region III Office routinely reviews the Radiation Protection Program and implementing procedures and their implementation.

Disposal of BRP demolition debris will be performed in accordance with the Radiation Protection Program and implementing procedures as applicable.

XI. RECORDKEEPING Recordkeeping requirements for landfill disposal of demolition debris are specified in BRP procedures. Revision 1-2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 26 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS As a minimum, these records will include:

Surface contamination monitoring reports and Bulk container assay records for each container which will include but not be limited to:

o Date and time the assay was performed, o Source of the demolition debris, o Mass, volume and composition of the demolition debris, o Landfill destination for the demolition debris, and o Assay results.

XII. ANALYSIS OF NO SIGNIFICANT ENVIRONMENTAL IMPACTS EVALUATION Consumers Energy finds, in compliance with 10 CFR 50.82(a)(6)(ii), that activities associated with this application involve no significant environmental impacts. The following evaluation in conjunction with the foregoing discussion supports that finding.

A. Will the proposed activity result in significant environmental impacts not previously reviewed?

No significant environmental impacts are expected from the disposal of demolition debris with trace concentrations of licensed radioactive materials in a State of Michigan licensed landfill or alternate licensed PCB landfill. Total volume of.

landfill waste projected for BRP decommissioning is 635,10D01.34 million cubic feet including 72,00142 000 cubic feet of radioactive waste and -563,0001.2 million cubic feet of demolition debris. In comparison, NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities."

(EGEIS) lists a radioactive waste volume for the reference boiling water reactor (BWR) of 18,975 cubic meters (670,096 cubic feet), including disposable containers.

Although the GEIS evaluation of waste dispesal volumes did not address the removalanddispesal-of-non-raioaec-tive-struetures-and-materials-beyond-4hat necessaryo4termninate4he-NR-C-4ieense-the-volume-of-waste-evaluatedin-he-GEIS (67u09eubieexe-eeds4he-etakoastlume-vneludingdemeitien-debris-and radioac-tive-waste-pr-jeetedforRPdeeommissionin 6 -5 eubiofeet-.The BRP potentially impacted waste volume of 518.000 cubic feet and the total other radwaste volume of 142.000 cubic feet (total of approximately 660,000 cubic feet) compares with the FGEIS reference BWR.

Attachment I Revision+42 September 16, 2004

NUCLEAR REGULATORY COMMISSION 27 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Non-radiological environmental impacts evaluated in the GEIS included:

Demography and human activities in the area,

Hydrology,

Aquatic resources/ecosystems in the area surrounding the plant site,

Terrestrial resources,

Endangered and threatened species,

Land use,

Air pollution control requirements,

Water pollution control requirements,

Hazardous materials and waste control,

Occupational safety, and

Public safety.

Radiological environmental impacts evaluated in the GEIS included:

Occupational radiation exposure,

Radiation exposure to the public,

Radioactive waste management systems,

Liquid radioactive effluents, and

Airborne radioactive effluents.

The FGEIS concludes that the major environmental impact of decommissioning is the commitment of small amounts of land for waste burial in exchange for reuse of the facility and site for other purposes. Since in many instances, such as at a reactor facility, the land is a valuable resource, return of this land to the commercial or public sector is highly desirable. Therefore, the FGEIS evaluation bounds disposal of all BRP demolition debris including disposal of the demolition debris containing trace concentrations of licensed radioactive materials requested by this application. Revision .1-2 September 15, 2004

Attachment 2 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 Proposed Revision to the Request for Approval of Proposed Disposal Procedures in Accordance with 10 CFR 20.2002 Submitted March 14, 2001, May 18, 2001, and June 20, 2001 September 15, 2004 27 Pages

NUCLEAR REGULATORY COMMISSION 1 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS For the reasons hereinafter set forth, it is requested that approval be granted to the Consumers Energy Big Rock Point Plant (BRP), as licensed by Facility Operating License DPR-6, Docket 50-155, issued on May 1, 1964, for procedures controlling the disposal of demolition debris in accordance with provisions of 10 CFR 20.2002. A description of the waste material for disposal that potentially contains licensed materials, including the physical and chemical properties important to risk evaluation, and the proposed manner and conditions of waste disposal is provided in the following sections. The content of this application follows the guidance of NUREG-1 101, Volume 1, Onsite Disposal of Radioactive Waste - Guidance for Disposal by Subsurface Burial, March 1986 as applicable.

I. PROPOSED ACTIVITIES This request for approval of proposed disposal procedures in accordance with the provisions of 10 CFR 20.2002 allows Consumers Energy to dispose of demolition debris originating from decommissioning activities at BRP in a State of Michigan licensed Type II landfill or in a licensed PCB waste disposal facility where landfill design and institutional controls are equal to or more restrictive than the requirements placed on a State of Michigan licensed Type II landfill. The request is justified in the analysis discussed in the later sections of this document.

II. BACKGROUND By letters dated June 18, 1997, and June 26, 1997, Consumers Energy notified the NRC, pursuant to 10 CFR 50.82(a)(1)(i), that BRP would permanently cease operation on August 30, 1997. On August 29, 1997, the reactor was permanently shutdown, ending 35 years of electric power generation. On September 22, 1997, another letter was forwarded to the NRC certifying that the fuel had been removed from the reactor vessel and placed in the spent fuel pool for storage.

The BRP site is located on the northeast shore of Lake Michigan in Charlevoix County in the northern part of Michigan's Lower Peninsula. The site is approximately 60 miles northeast of Traverse City, Michigan, and about 4 miles north of the small town of Charlevoix along US Route 31.

The reactor at the BRP was of relatively small size (75 MWe) and contained a significantly small radioactive source term, only about 10 percent that of a standard boiling water reactor (BWR). Consumers Energy's goal is to dismantle BRP in a safe, environmentally conscious, and cost effective manner. This action will result in the timely removal of the existing nuclear plant in accordance with the DECON option found acceptable to the NRC in its Final Generic Environmental Impact Statement on Decommissioning of Nuclear Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 2 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Facilities, NUREG-0586. Decommissioning activities started in June 1997, and is expected to be completed in 2005.

As a part of the decommissioning process, Consumers Energy plans to dismantle the individual structures when they are empty and when they have been decontaminated and radiologically surveyed, as required. It is estimated that 97.5 million pounds of predominately concrete debris will originate from the decommissioning project'.

Approximately one half of this is non-impacted (i.e., has never had the potential for neutron activation or to be exposed to licensed radioactive materials). The other half has a potential to contain residual surface activity and/or neutron activation products in a limited quantity. This submission deals with the disposition of demolition debris from the BRP decommissioning. Big Rock Point proposes to dispose of up to 3.05 million pounds at an alternate disposal facility licensed to accept PCB waste. This waste stream consists of painted structural steel in which non-liquid PCBs are contained within the dried paint matrix and is classified as PCB bulk product waste.

III. JUSTIFICATION 10 CFR 20, Subpart K, §20.2001 requires that licensed radioactive material be disposed of only through (1) transfer to an authorized recipient, (2) decay in storage, (3) release in effluents within the limits in §20.1301, or (4) as authorized under §§20.2002, 20.2003, 20.2004, or §20.2005. This request for approval of proposed disposal procedures demonstrates compliance with 10 CFR 20.2001 requirements prior to disposal of demolition debris in a State of Michigan licensed landfill.

For demolition debris at BRP, three decommissioning options have been considered.

(1) License Termination with Structures Intact This option would involve removal of licensed radioactive materials from the existing structures to residual radioactivity levels acceptable for termination of the license. Verification of achieving these residual radioactivity levels would require conducting a final status survey (FSS) for license termination on the remaining structures as well as the site environs. Specific disadvantages for application of this option at BRP include a delay in our management's environmental stewardship goal and commitment for restoration of the site to greenfield status. This option would also result in an increased expenditure of ratepayer decommissioning funds necessary to perform a much expanded FSS lAn additional 15.5 millions pounds of non-impacted asphalt will also be disposed of in accordance with this submittal; this asphalt was installed after decommissioning began in 1997 and was not included in the original waste estimate. Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 3 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS and demobilization followed by remobilization of the construction work force necessary for ultimate removal of site structures.

(2) Demolition Followed by License Termination The initial process is similar to license termination with structures intact.

Removal of licensed radioactive materials from existing structures to residual radioactivity levels acceptable for license termination with unrestricted access would still be performed. However, prior to performing the FSS, the remaining structures would be demolished and the concrete rubble left on site.

The FSS would then be performed on the site environs. After license termination, the concrete rubble could be used as construction fill or disposed of in a State of Michigan licensed landfill facility. While this methodology appears to be able to meet all NRC requirements and public health and safety goals, the disadvantages are that the debris would be expensive to stabilize over the long-term context. Furthermore, redevelopment of the site after license termination for other uses may require that debris be removed at some later date and relocated to another location on-site or off-site.

This option could be performed with somewhat less expenditure of ratepayer decommissioning funds than Option (1).

(3) Demolition and Disposal Followed by License Termination This option involves removal of licensed radioactive materials from the existing structures and installations. After decontamination of a work area, debris would be disposed of in a State of Michigan licensed landfill facility.

After removal of all demolition debris, the FSS would then be performed on the site environs, the license terminated by the NRC and the site released for unrestricted future use. This option is the most cost-effective use of ratepayer decommissioning funds and will result in the most expedient environmental restoration of the site.

The option that is most attractive to Consumers Energy and the public stakeholders is the disposition of demolition debris in a landfill prior to license termination; therefore, BRP has selected Option (3) as the preferred option. The criterion used in the License Termination Rule (10 CFR 20, Subpart E) for termination of the site license for unrestricted use is a total effective dose equivalent (TEDE) of 25 mrem/year. In comparison, the TEDE of this submittal for Option (3) (demolition debris disposal in a State of Michigan licensed landfill) is I mrem/year. Therefore, selection of Option (3) is Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 4 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS protective of the public health and safety, is consistent with As Low as Reasonably Achievable (ALARA), as well as being most cost-effective.

Consumers Energy is committed to conducting and completing decommissioning in a safe and cost efficient manner consistent with all regulatory requirements. Furthermore, Consumers Energy has determined that it is in the best interest to restore the site to greenfield conditions. Given the location of the site on the shore of Lake Michigan, the land is a valuable resource to the company and to the citizens of the area. The demolition debris that will originate from the demolition and removal of structures at BRP is included in this submittal. This demolition debris includes flooring materials, concrete, rebar, roofing materials, structural steel, the soils associated with digging up foundations and concrete and/or asphalt pavement or other similar solid materials.

While Options (1) and (2) can be conducted under 10 CFR 20, Subpart E, Consumers Energy believes that Option (3) should be conducted under Subpart K. Although Subpart E allows small quantities of detectable licensed material to be left onsite for license termination, until the license is terminated, no amount of licensed material may be released from the site unless it is authorized under Subpart K. Consumers Energy does not intend to make this submittal for intentional disposal of radioactive waste. However; it is recognized that a potential will exist for trace quantities of licensed material to be present in the demolition debris at levels below instrument detection capabilities. Therefore, this submittal is being made in accordance with provisions of 10 CFR 20.2002 because of the potential presence of licensed material in the demolition debris.

IV. Description of Waste A. Physical Properties The demolition debris that will originate from the demolition and removal of structures and paved surfaces at BRP includes flooring materials, concrete, rebar, roofing materials, structural steel, soils associated with digging up foundations and concrete and/or asphalt pavement or other similar solid materials.

The physical form of this demolition debris will be that of bulk material with various screen sizes ranging from particles the size of sand up to occasional monoliths with a volume of several cubic feet. For the purpose of analyses performed for this application, the demolition debris is assumed to be a homogenous mixture with a density of 94 pounds per cubic foot (1.5 g/cm 3 ).

The demolition debris will exist as a dry solid waste containing no absorbents or chelating agents. Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 5 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS B. Estimated Waste Volume and Burials Each Year It is estimated that the mass of potentially impacted demolition debris originating from the decommissioning of BRP will total approximately 48.7 million pounds.

With landfill density of 94 pounds per cubic foot, the estimated volume of potentially impacted demolition debris for disposal at a State of Michigan licensed landfill will be approximately 518,000 cubic feet, and 1.2 million cubic feet of combined impacted and non-impacted demolition debris. This represents approximately two percent of the annual volume of waste disposed at the landfill most likely to receive most BRP demolition debris.

For the purpose of analyses performed for this application, completion of landfill disposal of demolition debris is assumed to occur within a three-year period of time, with disposal of 50% of the total volume to occur in one year. BRP demolition debris will not be isolated or dedicated to a single burial cell at the landfill. Rather, it will be co-mingled with other landfill materials that are available for disposal when the demolition debris is delivered to the landfill facility.

Institutional controls required at a State of Michigan licensed landfill are discussed in a later section of this application. However, one of these requirements is that materials deposited in a burial cell are required to be covered with an interim 6-inch layer of soil each day. Final closure of the burial cell will not occur until the burial cell has reached its design capacity. Institutional controls for the licensed PCB landfill are equal or more restrictive that those for a licensed Michigan Type II landfill.

Therefore, if a burial for purposes of this application is defined as final closure of the burial cell in which BRP demolition debris has been deposited, the number of burials per year will be dependent on the total volume of other landfill materials delivered to the landfill for disposal. However, it should be noted that each day that demolition debris is deposited in a burial cell, it would be covered with an interim 6-inch layer of soil.

C. Radiological Characterization of Structural Concrete To date, over 200 core borings (2 inch diameter by 6 inch depth) have been taken from rooms or areas on the BRP site. Selection of the sampling location was biased toward areas expected to have the highest contamination potential. Each core has been analyzed onsite by gamma spectrometry and direct frisk to determine what types of radioactive material are present and how far the contaminants have penetrated into the concrete. The results of these onsite analyses are summarized in Revision 2 September 16, 2004

NUCLEAR REGULATORY COMMISSION 6 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Enclosure 1 to Big Rock Point's submittal dated June 20, 2001. In addition, portions of 14 core samples have been analyzed by an offsite laboratory (General Engineering Laboratories) at typical environmental monitoring lower limits of detection (LLD) using alpha and gamma spectrometry as well as liquid scintillation to analyze for the presence of the following radionuclides:

Ac-227 Ac-228 Ag-108m Ag-110m Am-241 C-14 Cd-109 Ce-144 Cm-242 Cm-243/244 Co-60 Cs-134 Cs-135 Cs-137 Eu-152 Eu-154 Fe-55 H-3 I-129 K-40 Mn-54 Ni-59 Ni-63 Nb-94 Pb-214 Pm-147 Pu-241 Pu-238 Pu-239/240 Ru-106 Sb-125 Sr-90 Tc-99 U-233/234 U-235/236 U-238 Zn-65 One-half inch thick, near surface wafers from 12 of the core samples were submitted to represent potential radioactive materials remaining after remediation of the structural surfaces. Laboratory analysis of these samples identified only Co-60, Cs-137, Fe-55 and H-3 at levels greater than the LLD values. K-40, Pb-214, U-233/234 and U-238 were also detected in these samples but at levels that were indistinguishable from naturally occurring background levels measured in plant concrete samples that were not contaminated by licensed radioactive materials. The results of these samples with concentration values representing the average concentration in the one-half inch thick wafer are detailed in Table 1. Copies of the General Engineering Laboratories Certificate of Analysis for these samples were included as Enclosure 2 to Big Rock Point's submittal dated June 20, 2001.

Attachment I Revision 2 September 16, 2004

NUCLEAR REGULATORY COMMISSION 7 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Table 1 Remediated Concrete Core Sample Results Radionuclide

,Sample Co-60 Cs-137 Fe-55 H-3 Number pCi/g pCi/g pCi/g pCilg 19 <LLD <LLD <LLD <LLD 31 <LLD <LLD <LLD <LLD 83 <LLD 0.130 0.088 <LLD <LLD 104 <LLD 0.094 0.054 <LLD <LLD 112 0.084 + 0.065 <LLD <LLD 6.24 +/- 2.51 123 <LLD <LLD <LLD 9.47 + 2.88 128 <LLD 0.166+/- 0.062 <LLD <LLD 7 <LLD <LLD <LLD <LLD 90 <LLD <LLD <LLD <LLD 149 0.458d0.114 <LLD <LLD <LLD 117 <LLD <LLD <LLD <LLD 100 <LLD <LLD <LLD <LLD 119* 2.47 +/- 0.739 <LLD <LLD <LLD 153* 0.292 +/- 0.140 0.282 +/- 0.128 <LLD <LLD

Remediated high surface contamination samples The final two core samples listed above were taken from areas having a high potential for surface contamination and are average values of subsurface samples taken at various concrete depths. Laboratory analysis of these samples identified only Co-60, Cs-137 and H-3. K-40, Pb-214, U-233/234 and U-238 were also detected in these samples but at levels that were indistinguishable from naturally occurring background levels measured in plant concrete samples that were not contaminated by licensed radioactive materials.

D. Calculated Licensed Radioactive Material Content of Demolition Debris Results of the radiological characterization of structural concrete and current remedial action contamination surveys were used to classify the surfaces as either uncontaminated, shallow surface contaminated or deep surface contaminated.

Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 8 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Uncontaminated surfaces were defined as surfaces having no detectable contamination as evidenced by historical records review, current remedial action contamination surveys and laboratory analysis of representative core samples.

Shallow surface contamination is defined as surfaces having no detectable contamination (> 5,000 dpm/1 00 cm2 total activity) as evidenced by contamination surveys performed after remedial action (if required) but detectable shallow subsurface contamination identified by laboratory analysis of representative core samples. Shallow subsurface contamination is assumed (based on core sample profiling) to penetrate to a depth of 1 inch after surface remediation.

Deep surface contamination is defined as highly contaminated surfaces prior to remediation with no detectable contamination as evidenced by contamination surveys performed after remedial action, but with some detectable deep subsurface contamination identified by laboratory analysis of representative core samples. This subsurface contamination is assumed to penetrate to a depth of 6 inches after surface remediation.

Based on the results of the radiological characterization of structural concrete on a room-by-room basis, a total surface area of 10,200 square feet have been calculated to have deep surface contamination. 51,835 square feet have been calculated to have shallow surface contamination and the remainder is considered to be uncontaminated. This results in a calculated 5,100 cubic feet of deep surface contaminated concrete and 4,320 cubic feet of shallow surface contaminated concrete.

Averaging the greater than LLD results from Table I and applying the resulting concentrations to the 4,320 cubic feet of shallow surface contaminated concrete and 5,100 cubic feet of deep surface contaminated concrete results in concentrations and total activity as reported in Table 2. Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 9 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Table 2 Volumetric Contamination of Remediated Surface Contaminated Concrete Radionuclide Concentration (pCi/g) Total Activity (mCi)

Co-60 0.83 0.613 Cs-137 0.17 0.126 H-3 7.86 5.806 Total 8.85 6.544 All 48.65 million pounds of impacted concrete will be treated as potentially contaminated. The volumes of 4,320 cubic feet of shallow and 5,100 cubic feet of deep contamination as calculated from structural characterization analyses, will not be separated from impacted concrete debris. Therefore, as a conservative estimate of activity potentially present, activity concentrations from Table 2 were applied to the impacted demolition debris mass of 48.65 million pounds resulting in total activity as reported in Table 3.

Table 3 Impacted Demolition Debris Total Activity (48.65 million pounds)

Radionuclide Concentration (pCi/g) Total Activity (mCi)

Co-60 0.83 18.4 Cs-137 0.17 3.8 H-3 7.86 175 Total 8.85 197 E. Requested Limiting Demolition Debris Concentration To allow operational flexibility and ensure monitoring capability, Consumers Energy requests a bounding principal gamma emitter concentration limit of 5 pCi/gm for licensed radioactive materials contained as trace contamination in demolition debris for disposal in a State of Michigan licensed Type II landfill or alternate landfill licensed for disposal of PCB wastes. Adjusting the total activity reported in Table 3 to a bounding principal gamma emitter concentration limit of 5 pCi/gm results in the bounding activity reported in Table 4. Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 10 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Table 4 Impacted Demolition Debris Bounding Activity (48.65 million pounds)

Radionuclide Concentration (pCi/g) Total Activity (mCi)

Co-60 4.15 92.1 Cs-137 0.85 19.0 H-3 39.3 875 Total 44.3 986 To ensure that the 5 pCi/gm principal gamma emitter limit is not exceeded, structural surfaces will be surveyed prior to demolition to verify that surface contamination does not exceed 5,000 dpm/1 00 cm2 averaged over areas appropriate for the detection system utilized and all demolition debris will be monitored by a bulk assay system with an alarm setpoint established at or below the 5 pCi/gm principal gamma emitter limit prior to disposal.

Establishment of this bounding concentration limit will ensure that any uncertainties in the content of licensed radioactive material in demolition debris sent to a State of Michigan licensed landfill or alternate landfill licensed for disposal of PCB wastes will not present a dose impact problem.

F. Dose Impacts Dose impacts of the requested impacted demolition debris bounding activity were evaluated by performing calculations using the Table 4 radionuclide concentrations as source terms (reference Big Rock Point Engineering Analysis, EA-BRP-RAE-04-01, Disposal of Demolition Debris at Environmental Quality Company, Revision 0 and EA-BRP-RAE-04-02, Disposal of Demolition Debris at Environmental Quality Company: Alternative, Revision 0.) These calculations are bounding because release at a principal gamma emitter limit of 5 pCi/gm is assumed for all 48.65 million pounds of impacted demolition debris. In practice, release surveys to a minimum detection limit of 5 pCi/gm of principal gamma emitters results in release of demolition debris from zero to 5 pCi/gm, or a mean of approximately 2.5 pCi/gm.

1. Transport Worker Dose Assessment An evaluation of transport worker dose was performed using MicroShield, Version 5.05, from Grove Engineering and site-specific assumptions including Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 11 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS bounding concentration values presented in Table 4. The transport system chosen for this evaluation was a roll-off container system with dimensions of 21.5 feet long, 8 feet wide and 3.5 feet high.

In addition to the above, the following assumptions were also applied to the analysis. In each case, the driver's seat is assumed to be 1 foot away from the cabin wall, which is conservatively assumed to be 0.12 inches thick, made of iron. The material hauler part of the truck is assumed to be made of iron with 0.25-inch thick sides, floor and tailgates. The distance between the hauler part and the driver's cabin is assumed to be 4 feet.

a. Transportationto a Licensed Type II Landfill:

It is assumed that three truck drivers will be used for the total duration of the project and that the number of loads transported will be divided equally between each driver. Given the anticipated volumes of the impacted demolition debris, combined with the assumptions of standard load volumes in tandem trailers, transport of 50% of demolition debris within a one-year period and the driving time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months per load to the landfill, each truck driver will be potentially exposed to radiation from residual radioactivity for 324 hours0.00375 days 0.09 hours 5.357143e-4 weeks 1.23282e-4 months . Applying the above assumptions, results in a calculated dose rate to the driver of 9.87E-04 mrem/hour or an annual dose of 0.320 mrem to each of the truck drivers.

b. Transportto a Licensed PCB Landfill:

Assume that two truck drivers will be used for transportation of PCB bulk product waste and that the number of loads transported will be divided equally between each driver. Given the maximum estimated 3.05 million pounds of PCB waste for disposal, combined with the assumptions of standard load volumes in tandem trailers, transport of all PCB waste within a one-year period and the driving time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months per load to the landfill, each truck driver will be potentially exposed to radiation from residual radioactivity for 180 hours0.00208 days 0.05 hours 2.97619e-4 weeks 6.849e-5 months . Applying the above assumptions, results in a calculated dose rate to the driver of 9.87E-04 mremlhour or an annual dose of 0.178 mrem to each of the truck drivers.

Output from the MicroShield analysis is provided as Attachment 3 to this submittal.

Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 12 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

2. Landfill Worker Dose Assessment An evaluation of landfill worker dose was performed using RESRAD, Version 6.0. For landfill operation, the landfill is assumed to close after placement of the demolition debris. Post-closure monitoring of the landfill is required by the State of Michigan for a 30-year period. Therefore, it is assumed that a member of the public, other than a landfill worker will not have access to a burial cell containing the demolition debris until 30 years after debris placement.

The following assumptions were made in the evaluation:

a. The most exposed individual at the landfill is a bulldozer operator, positioning and spreading the demolition debris and placing a soil cap on it at the end of the day.

b. The landfill most likely to receive BRP demolition debris currently has three bulldozer operators and, for purposes of this assessment, dose was assumed to be equally distributed between each bulldozer operator.

c. The 522,200 cubic feet (14,710 cubic meters) of impacted demolition debris are assumed to be deposited in a-uniform 3.71-meter thick, 3,965 square meter (0.98 acre) layer, assuming all demolition debris is in the licensed Type II landfill.

d. Based on the 0.98 acre surface area estimate of impacted demolition debris and a burial cell surface area of 8 acres, each landfill worker is assumed to spend 12.25 percent (0.98 acre/8 acres) of each worker's time working over or exposed to impacted demolition debris or 245 hours0.00284 days 0.0681 hours 4.050926e-4 weeks 9.32225e-5 months per occupational year of 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months . This total of 245 hours0.00284 days 0.0681 hours 4.050926e-4 weeks 9.32225e-5 months equates to a RESRAD outdoor time fraction of 0.028.

e. A 0.15 m soil cover (which is a daily cover requirement) was assumed.

No credit was taken for any other engineering controls required by the State of Michigan.

f. No credit was taken for shielding provided to the workers by the bulldozer.

g. The bounding concentration values presented in Table 4 were used as the impacted demolition debris source terms. Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 13 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

h. Doses will be distributed to workers at each landfill in proportion to the total quantity of radioactive material potentially present. Conservatively assuming a constant maximum level of 5.0 pCi/g, doses are proportionate to the weights shipped to each site.

Use of the above assumptions results in a calculated annual TEDE dose of 0.291 mrem for each Type II landfill worker and a weight-proportionate dose of 0.01 82 mrem for the PCB landfill worker. Output from the RESRAD analysis is provided as Attachment 4.

3. Landfill Resident / Farmer Dose Assessment An evaluation of dose to an individual member of the public was performed using RESRAD, Version 6.0. Post-closure monitoring of the landfill is required by the State of Michigan for a 30-year period. For purposes of this evaluation, it is assumed that a residence, including a basement to the residence and a vegetable garden, is established on the burial cell containing the demolition debris 30 years after debris disposal.

The following assumptions were made in the evaluation:

a. RESRAD exposure pathways are active for the Resident / Farmer scenario except for the radon pathway (not regulated by the NRC).

b. The impacted demolition debris is assumed to be soil like material with the bounding concentration values presented in Table 4 even though its density is somewhat higher than most soils. Additionally, resuspension of demolition debris radioactivity is not expected to vary significantly from that for soil. Therefore, the RESRAD default soil parameters are considered appropriate for use in this analysis.

c. It is assumed that all licensed radioactive material in the impacted demolition debris is dispersed throughout the volume of impacted material originating at BRP and no dilution of the demolition debris occurs from other landfill materials deposited in the burial cell. This is very conservative since Michigan law requires a 6-inch soil cover over the debris at the end of each day and the demolition debris is expected to be only two percent of the total waste volume processed at the landfill over a one-year period.

d. For the Resident / Farmer scenario, it is assumed that the resident spends 50 percent of the time indoors, 25 percent outdoors at the site, and 25 Attachment l Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 14 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS percent of the time away from the site. These assumptions are consistent with those suggested in the NRC Policy and Guidance Directive PG-8-08, Scenarios for Assessing Potential Doses Associated with Residual Radioactivity.

e. Fifty percent effectiveness is assumed for the leachate collection system required by the State of Michigan (resulting in a 50 percent reduction in calculated annual dose). Also, the required 18-inch infiltration layer, 24-inch erosion layer and 6-inch earthen material layer capable of sustaining native plant growth are considered to be intact at the end of the 30-year period.

f. No credit is taken for landfill material originating elsewhere which may be deposited on top of the demolition debris.

g. The 522,200 cubic feet (14,710 cubic meters) of impacted demolition debris are assumed to be deposited in a uniform 3.71-meter thick, 3,965 square meter (0.98 acre) layer, assuming all demolition debris is buried in the licensed Type II landfill.

h. For the RESRAD model, root depth was extended from the default value of 0.9 m to a depth of 1.4 m. This was done to ensure communication between vegetation and the contaminated zone.

i. All other RESRAD parameters were set at their default values for this evaluation. An Engineering Analysis was performed on RESRAD parameter selections and concluded that, when applied to the northern Michigan climate and State of Michigan licensed Type II landfill requirements discussed in Section VIII, the use of default parameters will result in conservative dose estimates.

j. Doses will be distributed to residents at each landfill in proportion to the total quantity of radioactive material potentially present. Conservatively assuming a constant maximum level of 5.0 pCi/g, doses are proportionate to the weights buried at each site.

Applying the above assumptions results in a calculated maximum annual dose of 0.0178 mrem for a resident / farmer living at the Type II landfill site. This maximum annual dose occurs the first year of public access following the 30-year post-closure monitoring period. Using the assumption of weight proportionality, resident farmer living at the PCB landfill site would receive an Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 15 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS annual dose of 0.001 mrem. Output from the RESRAD analysis is provided as Attachment 5 to this submittal.

4. Dose Impact Conclusions Assuming that all impacted demolition debris would be released for State of Michigan licensed Type II landfill disposal at a bounding principal gamma emitter concentration limit of 5 pCi/gm as trace contamination in demolition debris would result in a maximum dose impact to an individual member of the public of 0.320 mrem/year to each of three transport workers. Maximum dose to each landfill worker was calculated to be 0.291 mrem/year during impacted demolition debris disposal. Maximum calculated dose to a resident / fanner was calculated to be 0.018 mrem/year which would not occur until after completion of the required 30-year post-closure monitoring period. These maximum calculated doses are well below the public dose objective of 1 mrem/year. Annual doses associated with disposal of demolition debris classified as PCB bulk product waste at a licensed PCB waste facility with design and institutional controls equal or greater that the a Type II landfill are 0.178 mrem to each of the truck drivers, 0.018 mrem to a landfill worker and 0.001 mrem to a resident farmer. If the entire estimated quantity of PCB bulk product waste were sent to the alternate disposal facility, doses associated with disposal at the licensed Type II landfill would be reduced by the quantities above.

Actual maximum dose impact to an individual member of the public is expected to be much less than these calculated values using a bounding principal gamma emitter concentration limit of 5 pCi/gm.

To ensure that the 5 pCi/gm principal gamma emitter limit is not exceeded, structural surfaces will be surveyed prior to demolition to verify that surface contamination does not exceed 5,000 dpm/100 cm2 averaged over areas appropriate for the detection system utilized and all demolition debris will be monitored by a bulk assay system with an alarm setpoint established at or below the 5 pCi/gm principal gamma emitter limit prior to disposal.

G. Prohibition on Burial of Hazardous Waste Hazardous waste as defined in the regulations of the Environmental Protection Agency (EPA), 40 CFR Parts 260 through 265, is not permitted to be included in the BRP demolition debris. Hazardous waste is required to be disposed of in a manner set out in EPA regulations and in accordance with applicable local and State laws Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 16 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS and codes, and will not be disposed of in conjunction with the debris considered here.

V. PACKAGING OF WASTE Big Rock Point demolition debris to be disposed of at a State of Michigan licensed Type II landfill or a licensed PCB landfill will not be packaged. Since the radiological survey process used to determine that the demolition debris is acceptable for landfill disposal will ensure that trace quantities of licensed material potentially present in the demolition debris are at levels below the requested bounding concentration limit, BRP demolition debris will be processed the same as debris generated from the demolition of any non-nuclear industrial facility.

The existing Radiation Protection Program, which is continually audited by the NRC, will ensure the radiological safety of BRP workers during generation and packaging of demolition debris. The dose evaluations discussed previously demonstrate that dose to members of the public from transportation and disposal of demolitions debris would not be measurable with state-of-the-art personnel monitoring instrumentation and is insignificant in comparison to the average annual dose received by individuals from natural sources (approximately 300 mrem per year).

Demolition debris will be transported from the BRP site to the landfill facility by truck transportation using either of three types of truck transport systems that are generally the common practice for carrying demolition debris. These transport systems include a roll-off container system, a dual-trailer mule system or a wide-bodied demolition hauler. Big Rock Point currently utilizes a dual-trailer mule (tandem trailer) system.

Roll-off container systems have the dimensions of 21.5 feet long by 8 feet wide by 3.5 feet high. Dual-trailer mule systems use two trailers, each having the dimensions of 50 feet long by 8 feet wide by 5 feet high. Wide-bodied demolition haulers have the dimensions of 30 feet long by 8 feet wide by 6 feet high.

Type II landfills licensed by the State of Michigan and PCB landfills licensed by the State of Michigan and the U.S. Environmental Protection Agency are required to implement controls to isolate the contents of burial cells from the environment. These controls will provide isolation of the BRP demolition debris from the environment over a reasonable period of time similar to the use waste packaging. The controls are discussed in Section VIII, Nature of the Burial Site.

Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 17 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS VI. BURIAL LOCATION The State of Michigan licensed Type II landfill selected for burial of BRP demolition debris will be located within approximately 60 miles of the BRP site. The facility selected for disposal of PCB bulk products wastes is located approximately 275 miles from the BRP site.

The State of Michigan Solid Waste Management Act Administrative Rules Promulgated Pursuant To Part 15 Of the Natural Resources and Environmental Protection Act, 1994 Pa 45 1, As Amended contains restrictions on the location of Type II landfill facilities.

Among these are restrictions on groundwater isolation, horizontal isolation distances, floodplains, wetlands, fault areas and seismic impact zones, and unstable areas. These restrictions are discussed in Section VIII, Nature of the Burial Site.

VII. INSTITUTIONAL CONTROLS Part 115 of the State of Michigan Administrative Rules contains institutional controls that restrict access to Type II licensed landfills. Licensing requirements for the landfill selected for disposal of PCB bulk products wastes are considered equal or more restrictive than those for licensed Type II landfills. The landfill operator is required to control public access to the landfill and prevent unauthorized vehicular traffic and illegal dumping of wastes by using artificial or natural barriers, or both, as appropriate.

After the final closure of a burial cell, the landfill operator is required to conduct post-closure care for not less than 30 years. This post-closure care includes:

Maintaining the integrity and effectiveness of any final cover,

Maintaining, operating, and monitoring the leachate collection system,

Monitoring the groundwater,

Monitoring all secondary collection systems and leak detection systems, and

Maintaining and operating the gas monitoring and collection system.

VIII. NATURE OF THE BURIAL SITE The Type II landfill where the BRP demolition debris will be sent for disposal will meet State of Michigan Part 15 Administrative Rules that will limit migration of licensed radioactive material potentially mixed with the demolition debris in trace amounts. These requirements include but are not limited to:

Location restrictions,

A composite liner, Attachment 1 Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 18 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

Leachate collection and removal systems,

Leak detection systems,

Daily 6 inch interim soil covers,

Explosive gas control and monitoring,

Groundwater monitoring,

Surface and Groundwater Performance,

Run-On and Run-Off Control Systems, and

Final cover composite liner designed to minimize infiltration and erosion.

A. Location Restrictions The location of each burial cell will be isolated from groundwater sources.

Permanent minimum clearances of ten feet to the natural groundwater level and 7 feet to a permanently depressed groundwater level is required to be maintained from the top of the primary liner.

The active work area at the landfill is required to not be located closer than 100 feet to adjacent property lines or road rights-of-way or closer than 300 feet to domiciles that exist at the time a landfill license is requested. It is also not allowed to be located within 400 feet of inland lakes and streams or within 2,000 feet of the Great Lakes. The active work area is also required to be a minimum of 2,000 feet from wells that serve Type I and Type Ha water supplies and a minimum distance of 800 feet from wells that serve Type 1Ib and Type III public water supplies.

If a landfill is located within a floodplain, the landfill operator is required to demonstrate that:

The cell will not restrict the flow of the 100-year flood,

The cell will not reduce the temporary water storage capacity of the floodplain,

The cell will not result in washout of solid waste so as to pose a hazard to human health and the environment,

The cell does not encroach upon the floodway and will not increase upstream or downstream flood stages,

The cell has a natural or compacted soil base which is not less than 10 feet thick,

The distance from the normal water line of the water body to the solid waste boundary of the landfill will not be less than 500 feet, and Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 19 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS The design of the landfill will include a dike to preclude floodwater inundation with a top elevation that is not less than 5 feet above the 100-year flood elevation.

Landfills are not allowed to be located in wetlands unless extensive measures are taken for protection of the wetlands.

Landfill burial cells are not permitted to be located within 200 feet of a fault that has had displacement in holocene time, unless the landfill operator demonstrates that an alternative setback distance of less than 200 feet will prevent damage to the structural integrity of the cell and will be protective of human health and the environment. They are also not permitted to be located in seismic impact zones, unless the landfill operator demonstrates that all containment structures, including liners, leachate collection systems, and surface water control systems, are designed to resist the maximum horizontal acceleration in lithified earth material for the site.

B. Composite Liners Burial cells are required to be constructed with a composite liner and a leachate collection system that is designed and constructed to maintain less than a 1-foot depth of leachate over the liner, excluding the sump.

Burial cells are required to be located, designed, and constructed so that the risks posed by leakage through the composite liner are minimized. To do so, a cell is required to be either a monitorable cell that is located over a natural soil barrier so as to restrict the migration of leakage from the unit or designed with a double liner system that is capable of detecting and collecting leakage through the primary composite liner.

C. Leachate Collection and Removal Systems Each burial cell is required to have a leachate collection system that is designed and constructed to maintain less than a 1-foot depth of leachate over the primary liner.

To do so, the system is required to be designed to do all of the following:

Limit the head at any point in the system, excluding the sump, to not more than 1 foot,

Extend across the entire bottom of the system,

Be chemically resistant to the waste that is managed in the landfill and the leachate that is expected to be generated and be of sufficient strength and Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 20 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS thickness to prevent collapse under the pressures that are exerted by overlying wastes, waste cover materials, and equipment that is used at the landfill,

Minimize clogging during the active life and postclosure care period,

Drain leachate to sumps using pumps that are of a sufficient size to collect and remove liquids from the sump and prevent liquids from backing up into the drainage layer. The design of each sump and removal system provides a method for measuring and recording the volume of liquids removed and the depth of leachate in the sump.

A secondary collection system is required to be provided and be capable of detecting, collecting, and removing leaks of hazardous constituents at the earliest practicable time through all areas of the top liner that are likely to be exposed to waste or leachate during the active life and postclosure care period.

The landfill operator is required to remove leachate from a burial cell as frequently as necessary to ensure that the leachate depth on the liner, excluding the sump, is not more than 1 foot, except after a significant storm event. The leachate depth on the liner is not allowed to be more than 1 foot for more than seven days after a significant storm event. A significant storm event is a storm that generates 0.1 inches or more of rainfall in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

D. Leak Detection Systems Each burial cell is required to have a leak detection system. For unmonitorable units, the secondary collection system is also a leak detection system. A response flow rate is established in the operating license for each landfill to evaluate the performance of a leak detection system.

If the average daily flow rate removed from the sump of a leak detection system is more than the action flow rate for that burial cell, the landfill operator is required to evaluate the chemical characteristics of liquid in the leak detection system by sampling and analyzing the system and evaluating for the presence of a leak by a statistical test, a trend analysis, or other means. Before solid waste is placed in any new burial cell that has a leak detection system, the landfill operator may, at his discretion, establish a baseline concentration of constituents in the secondary collection system based on an analysis of representative samples from the system.

The landfill operator must conduct required response actions if monitoring of the leak detection system determines that both of the following apply to liquid that is removed from the system: Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 21 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

The average daily flow rate is more than the response flow rate that is established for the unit and

The liquid contains hazardous substances indicative of leachate from the unit.

A landfill operator who is required to conduct response actions is required to take all of the following actions:

Within seven days of a determination that the response flow rate has been exceeded, notify the State of Michigan, in writing, that the response flow rate has been exceeded,

Submit a preliminary written assessment to the State of Michigan within 14 days of a determination that the response flow rate has been exceeded. A preliminary written assessment is required to include all of the following information for the landfill cell in which the response flow rate was exceeded:

o The amount of liquids removed from the leak detection system, o The likely sources of liquids, including the depth of leachate in the leachate collection system, o The possible location, size, and cause of any leaks, and o The short-term actions taken and planned.

Determine, to the extent practicable, the location, size, and cause of any leak.

Determine whether waste receipt should cease or be curtailed, whether any waste should be removed from the landfill cell for inspection, repairs, or controls, and whether or not the cell should be closed.

Determine any other short-term and longer-term actions to be taken to mitigate or stop any leaks.

After a determination that the response flow rate has been exceeded, and for as long as the flow rate in the system exceeds the response flow rate, the landfill operator is required to submit to the State of Michigan, within 30 days of the end of the calendar quarter, a report that summarizes the results of any remedial actions taken and planned.

Attachment I Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 22 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

To make the leak or remediation determinations required, the landfill operator is required to do all of the following:

o Assess the source of liquids and amounts of liquids by source, o Conduct a fingerprint, hazardous constituent, or other analysis of the liquids in the system to identify the source of liquids and possible location of any leaks and the hazard and mobility of the liquid, and o Assess the seriousness of any leaks in terms of potential for escaping into the environment or document why the assessments are not needed.

E. Daily Six-Inch Soil Covers The landfill operator is required to cover disposed of solid waste with 6 inches of earthen material at the end of each operating day or at more frequent intervals, if necessary, to control disease vectors, fires, odors, blowing litter, and scavenging. If clay or other low-permeability material is used as daily cover, then the operator is required to scrape back the previous day's cover to allow the free movement of liquids and gases through the landfill.

If an active burial cell will lie idle for a period of three months or more before additional lifts are constructed, the landfill operator is required to place 1 foot of compacted cover, which may include the 6-inch daily cover, on the surface to minimize nuisance conditions.

F. Explosive Gas Control and Monitoring The landfill operator is required to ensure that the concentration of methane gas generated by the facility is not more than 25 percent of the lower explosive limit for methane in facility structures, excluding gas control or recovery system components, and the leachate collection system and that the concentration of methane gas is not more than the lower explosive limit at or beyond the facility property boundary. To demonstrate compliance with this requirement the landfill operator is required to implement a routine methane monitoring program.

G. Groundwater Monitoring Detection monitoring is required at all required groundwater monitoring wells. At a minimum, a detection-monitoring program for a landfill is required to include monitoring for all of the following constituents: Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 23 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS

The listed primary indicators and pH, at least quarterly during the active life and semiannually during the postclosure period and

The following constituents listed at least semiannually during the active life of the facility and the postclosure period:

o Heavy metals that are listed, o Listed primary volatile organic constituents, and o Listed secondary organic constituents.

The landfill operator of a cell that contains a secondary collection system may conduct sampling and analysis for listed primary indicators in place of the heavy metals if all of the following conditions are met:

Leachate monitoring shows that the concentration of all of the indicators in leachate is not less than ten times the concentration in groundwater and

Secondary collection system monitoring shows all of the following:

o That the allowable flow rate has not been exceeded, o That the concentration of two or more indicators in the system is not more than the following threshold values for two consecutive sampling events:

For chlorides, 250 mg/I,

For iron, 0.3 mg/I,

For sulfates, 250 mg/I,

For total inorganic nitrogen, 10 mg/I, and

For total dissolved solids, 500 mg/I.

o That listed volatile organics have not been detected in the secondary collection system, o That the listed concentration of metals has not exceeded 1/10 the specified value,

The unit is a monitorable unit, and

The concentration of the indicators in groundwater is normally distributed. Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 24 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Assessment monitoring is required at a landfill if a statistically significant increase over background has been detected for one or more of the listed constituents.

Within 90 days of the triggering of an assessment monitoring program, and annually thereafter, the landfill operator is required to sample and analyze the groundwater for all constituents listed in 40 CFR part 258, Appendix II. A minimum of one sample from each downgradient well is required to be collected and analyzed during each sampling event. For any constituent that is detected in the downgradient wells as a result of the complete Appendix II constituent analysis, a minimum of four independent samples from each background and downgradient well are required to be collected and analyzed to establish background for the constituents.

H. Surface and Groundwater Performance Operation of a State of Michigan licensed landfill is not allowed to cause a discharge of pollutants into waters of the United States, including wetlands, that is in violation of any of the requirements of the federal clean water act, including the national pollutant discharge elimination system (NPDES) requirements under Section 402 of the Federal Clean Water Act. Also, the landfill is not allowed to cause the discharge of a nonpoint source of pollution to waters of the United States, including wetlands, that is in violation of any of the requirements of an areawide or statewide water quality management plan that has been approved under Section 208 or 319 of the Federal Clean Water Act.

To demonstrate compliance with these requirements, the landfill operator is required to conduct a surface water-monitoring program approved by the State of Michigan for any surface water that may receive run-off from the active work area.

Monitoring results are required to be submitted to the State of Michigan not more than 30 days after the end of the calendar quarter.

I. Run-On and Run-Off Control Systems Two systems are required to control the flow of rainwater over burial cells. A run-on control system is required to prevent flow onto the active portion of the landfill during the peak discharge from a 25-year, 24-hour storm. Also, a run-off control system from the active portion of the landfill is required to collect and control at least the water volume that results from a 24-hour, 25-year storm.

J. Final Cover Composite Liner A final cover system is required to be installed on each burial cell which is designed to minimize infiltration and erosion and which is comprised of an erosion layer Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 25 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS underlain by an infiltration layer. The final cover system is required to be comprised of the following components:

An infiltration layer that is comprised of either a minimum of 18 inches of earthen material that has a permeability which is less than or equal to 1.0 x 10 5 cm/sec or a bentonite geocomposite liner which is underlain by not less than 18 inches of earthen material to protect the liner from waste and minimize the effect of settlement.

An erosion layer that consists of both a soil layer which is not less than 2 feet thick, which is immediately above the composite cover liner, and which is designed to do all of the following:

o Provide for the lateral drainage of precipitation off the cover of the landfill, o Minimize frost penetration into the infiltration layer, and o Protect the flexible membrane liner from root penetration, ultraviolet light, and other deleterious effects.

A minimum of 6 inches of earthen material capable of sustaining native plant growth is required to be placed over the final cover system. To prevent the ponding of water on completed fill surfaces, the grading contours are required to be sufficient to prevent the development of local depressions due to post construction settlement.

Slopes of the final cover are required to be not less than four percent at any location.

IX. BURIAL PROCEDURES Please refer to Section VIII, Nature of the Burial Site regarding the burial of BRP demolition debris at State of Michigan licensed landfill facilities.

X. RADIATION SAFETY PROCEDURES BRP is currently conducting decommissioning activities under a Radiation Protection Program and implementing procedures that comply with NRC regulatory requirements contained in 10 CFR 20, Standards for Protection Against Radiation. The Radiation Protection Program and implementing procedures are a requirement of the BRP Defueled Technical Specifications 6.6.1 and 6.6.2. The NRC Region III Office routinely reviews the Radiation Protection Program and implementing procedures and their implementation. Revision 2 September 15, 2004

NUCLEAR REGULATORY COMMISSION 26 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS Disposal of BRP demolition debris will be performed in accordance with the Radiation Protection Program and implementing procedures as applicable.

XI. RECORDKEEPING Recordkeeping requirements for landfill disposal of demolition debris are specified in BRP procedures.

As a minimum, these records will include:

Surface contamination monitoring reports and Bulk container assay records for each container which will include but not be limited to:

o Date and time the assay was performed, o Source of the demolition debris, o Mass, volume and composition of the demolition debris, o Landfill destination for the demolition debris, and o Assay results.

XII. ANALYSIS OF NO SIGNIFICANT ENVIRONMENTAL IMPACTS EVALUATION Consumers Energy finds, in compliance with 10 CFR 50.82(a)(6)(ii), that activities associated with this application involve no significant environmental impacts. The following evaluation in conjunction with the foregoing discussion supports that finding.

A. Will the proposed activity result in significant environmental impacts not previously reviewed?

No significant environmental impacts are expected from the disposal of demolition debris with trace concentrations of licensed radioactive materials in a State of Michigan licensed landfill or alternate licensed PCB landfill. Total volume of landfill waste projected for BRP decommissioning is 1.34 million cubic feet including 142,000 cubic feet of radioactive waste and 1.2 million cubic feet of demolition debris. In comparison, NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, " (FGEIS) lists a radioactive waste volume for the reference boiling water reactor (BWER) of 18,975 cubic meters (670,096 cubic feet), including disposable containers.

Attachment I Revision 2 September 16, 2004

NUCLEAR REGULATORY COMMISSION 27 BIG ROCK POINT PLANT REQUEST FOR APPROVAL OF PROPOSED DISPOSAL PROCEDURES UNDER 10 CFR 20.2002 PROVISIONS The BRP potentially impacted waste volume of 518,000 cubic feet and the total other radwaste volume of 142,000 cubic feet (total of approximately 660,000 cubic feet) compares with the FGEIS reference BWR.

Non-radiological environmental impacts evaluated in the GEIS included:

Demography and human activities in the area,

. Hydrology,

Aquatic resources/ecosystems in the area surrounding the plant site,

Terrestrial resources,

Endangered and threatened species,

Land use,

Air pollution control requirements,

Water pollution control requirements,

Hazardous materials and waste control,

Occupational safety, and

Public safety.

Radiological environmental impacts evaluated in the GEIS included:

Occupational radiation exposure,

Radiation exposure to the public,

Radioactive waste management systems,

Liquid radioactive effluents, and

Airborne radioactive effluents.

The FGEIS concludes that the major environmental impact of decommissioning is the commitment of small amounts of land for waste burial in exchange for reuse of the facility and site for other purposes. Since in many instances, such as at a reactor facility, the land is a valuable resource, return of this land to the commercial or public sector is highly desirable.

Therefore, the FGEIS evaluation bounds disposal of all BRP demolition debris including disposal of the demolition debris containing trace concentrations of licensed radioactive materials requested by this application.

Attachment I Revision 2 September 16, 2004

Attachment 3 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 MICROSHIELD ASSESSMENT OF TRANSPORTATION WORKER (ROLL_3.MS5 and 2NDROLL.MS5)

September 15, 2004 4 Pages

MicroShield v5.05 (5.05-00326)

CONSUMERS ENERGY COMPANY Page : 1 File Ref:

DOS File: ROLL_3.M55 Date:'

Run Date: July 21, 2004 By: :.

Run Time: 8:26:26 AM *Checked:

Duration: 00:00:02 Case

Title:

Rolloff Recalc

-Description: Density 0.667 (25,000 lbs)

Geometry: 13 - Rectangular Volume Source Dimensions Length 655.32 cm 21 ft 6.0 in Width 243.84 cm 8 ft Height 106.68 cm 3 ft 6.0 in Dose Points X Y z

1 808.672 cm 53.34 cm 121.72 cm 26.ft 6.4 inl ft 9.0 in3 ft 11-.9 in.

Shields Shield Name Dimension Material Density Source 1.70e+07 cmNBS ConcretL.667 Shield 1 .64 cm Iron 7.86 Shield 2 121.92 cm Air 0.00122 Shield 3. .305 cm Iron 7.86 Shield 4 30.48 cm Air 0.00122 Air Gap Air 0.00122 Source Input Grouping Method : Actual Photon Energies .

Nuclide curies becquerels gCi/cm3- Bq/cm3 Ba-137m 9.1919e-006 3.4010e+005 5.3922e-007 1.9951e-002 Co-60 4.7219e-005 1.7471e+006 2.7700e-006. 1.0249e-001 Cs-137 9.7166e-006 3.5952e+005 5.7000e-007 2.1090e-002 Fe-55 H-3 4.4662e-004 1.6525e+007 2..6200e-005 9.6940e-001 Buildup The material reference is.:.Source Integration Parameters X Direction 10 Y Direction 20 Z Direction 20 Results Energy Activity Fluence Rate Fluence Rate Exposure Rate Exposure Rate MeV photons / sec MeV/cm 2 7sec MeV/cm2/sec mR/hr

mR/hr No Buildup With Buildup No Buildup With Buildup 0.0318 7.041e+03 2.190e-30 -1.063e-29 1.824e-32 8.854e-32 0.0322 1.299e+04 2.602e-29 9.640e-29 2.094e-31

7.758e-31 0.0364 4.727e+03 9..538e-23 4.974e-22 5.419e-25 - 2.826e-24 0.6616 3.060e+05 7.134e-03 2.187e-02 1.383e-05 4.240e-05 0.6938 2.850e+02 7.193e-06 2.152e-05 1.389e-08 -4.156e-08

Page 2 DOS File: ROLL_3.MS5 Run Date: July 21, 2004 Run Time: 8:26:26 AM Duration: 00:00:02

.Energy Activity Fluence Rate Fluence Rate Exposure Rate Exposure Rate MeV photons/sec MeV/cm 2 Tsec MeV/cm2 /sec mR/hr. mR/hr No Buildup With Buildup No Buildup With Buildup 1.1732 1.747e+06 1.057e-01 2.474e-01 1.888e-04

4.421e-04 1.3325 1.747e+06 1.303e-01 2.897e-01 2.260e-04 5.026e-04 TOTALS: 3.825e+06 2.431e-01 5.590e-01 4.287e-04 9.871e-04

MicroShield v5..05 (5.05-00326)

CONSUMERS ENERGY COMPANY Page :1 File Ref:

DOS File: 2NDROLL.MS5 Date:

Run Date: July 21, 2004 By:

Run Time: 11:37:56 AM Checked:

Duration: 00:00:02 Case

Title:

Rolloff Recalc

Description:

Density:0.667 (25,000 lbs)

Geometry: 13 - Rectangular Volume Source Dimensions Length 655.32 cm 21 ft 6.0 in Width 243.84 cm 8 ft Height 106.68 cm 3.ft 6.0 in Dose Pointh X Y . z

1 1466 cm 53.34 cm 121.72 cm 48 ft 1.2 in1 ft 9.0 in3 ft 11.9 in.

Shields Shield Name Dimension Material Density Source 1.70e+07 cmNBS Concrete.667 Shield 1 1.921 cm Iron 7.86 Shield 2 655.32 ciNBS ConcretEi.667 Shield 3 .64 cm Iron 7.86 Shield 4 121.92 cm Air 0.00122 Shield 5 .305 cm Iron 7.86 Shield 6 30.48 cm Air 0.00122 Air Gap Air 0.00122 Source Input Grouping Method : Actual Photon Energies Nuclide curies becguerels Aj.Ci/cm3 Bq/cm3 Ba-137m 9.1919e-006 3.4010e+005 5.3922e-007 1.9951e-002 Co-60 4.7219e-005 1.7471e+006 2.7700e-006 1.0249e-001 Cs-137 9.7166e-006 3.5952e+005 5.7000e-007 2.1090e-002 Fe-55 H-3 4.4662e-004 1.6525e+007 2.6200e-005 9.6940e-001 Buildup The material reference is : Shield 1 Integration Parameters X Direction 10 Y Direction 20 Z Direction 20 Results Enerqy Activit Fluence Rate Fluence Rate Exposure Rate Exposure Rate MeV photons/sec MeV/cm2/sec MeV/cm2/sec mR/hr mR/hr No Buildup With Buildup No Buildup *With Buildup 0.0318 .7.041e+03 1.164e-261 1.442e-31 9.696e-264 1.201e-33

0. 0322 1.299e+04 1.230e-253 2.704e-31 9.901e-256 2.176e-33 0.0364 4.727e+03 1.624e-187 1.185e-31 9.229e-190 *6.733e-34 0.6616 3.060e+05 2.437e-19 3.461e-17 4.725e-22 6.710e-20

Page -

DOS File: 2NDROLL.MS5 Run Date: ~July 21, 2004 Run Time: 11:37:56 AM Duration: 00:00:02

Energy Activit Fluence Rate Fluence Rate Exposure Rate Exposure-Rate MeV photons/sec MeV/cm 2 /sec MeV/cm2 /sec mR/hr. mR/hr No Buildup With Buildup No Buildup With Buildup

0.6938 2.850e+02 5.163e-22 6.894e-20 9.969e-25 1.33le-22 1.1732 1..747e+06 1.585e-14 9.146e-13 2.832e-17 1.634e-15 1.3325 1.747e+06 1.044e-13 4.904e-12 1.811e-16 8.507e-15 TOTALS: 3.825e+06 1.202e-13 5.818e-12 2.094e-16 1. 014e-14

Attachment 4 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 RESRAD ASSESSMENT OF LANDFILL WORKER DOSE (Worker.rad)

September 15, 2004 18 Pages

Kt~bFALI, version ba.l TV Limit - 0.5 year 07/27/2004 09:29 Page 1 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Table of Contents 6

0 .,1 1b/I Wor/t 0 Part I: Mixture Sums and Single Radionuclide Guidelines Dose Conversion Factor (and Related) Parameter Summary ... 2 Site-Specific Parameter Summary .......................... 3 Summary of Pathway Selections ............................ .7 Contaminated Zone and Total Dose Summary ................. 8 Total Dose Components Time - 0.000E+00 .................................... 9 Time - 1.OOOE+00 .................................... 10 Time - 3.OOOE+00 .................................... 11 Time - 1.OOOE+01 .................................... 12 Time - 3.OOOE+01 .................................... 13 Time - 1.OOOE+02 .................................... 14 Time - 3.000E+02 .................................... 15 Time - 1.OOOE+03 .................................... 16 Dose/Source Ratios Summed Over All Pathways .............. 17 Single Radionuclide Soil Guidelines ...................... 17 Dose Per Nuclide Summed Over All Pathways ................ 18 Soil Concentration Per Nuclide ........................... 18

RESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:29 Page 2 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Dose Conversion Factor (and Related) Parameter Summary File: FGR 13 Morbidity I l Current l Parameter Menu I Parameter I Value Default l Name I 4-B-1 I Dose conversion factors for inhalation, mrem/pCi:

B-1 Co-60 l 2.190E-04 2.190E-04 l DCF2( 1)

B-1 I Cs-137+D l 3.190E-05 3.190E-05 lDCF2( 2)

B-1 I H-3 l 6.400E-08 6.400E-08 I DCF2( 3)

I D-1 I Dose conversion factors for ingestion, mrem/pCi:

D-1 I Co-60 l 2.690E-05 2.690E-05 l DCF3( 1)

D-1 I Cs-137+D l 5.000E-05 5.OOOE-05 l DCF3( 2)

D-1 I H-3 I 6.400E-08 6.400E-08 D 0CF3( 3)

D-34 I Food transfer factors: I.

D-34 ICo-60 , plant/soil concentration ratio, dimensionless l 8.OOOE-02 8.000E-02 l RTF( 1,1)

D-34 I Co-60 , beef/livestock-intake ratio, (pCi/kg)/(pCi/d) 2.OOOE-02 2.OOOE-02 l RTF( 1,2)

D-34 I Co-60 , milk/livestock-intake ratio, (pCi/L)/(pCi/d) l 2.OOOE-03 2.OOOE-03 l RTFC 1,3)

D-34 D-34 I Cs-137+D , plant/soil concentration ratio, dimensionless 4.000E-02 4.OOOE-02 l RTF( 2,1)

D-34 I Cs-137+D , beef/livestock-intake ratio, (pCi/kg)/(pCi/d) l 3.000E-02 3.OOOE-02 l RTF( 2,2)

D-34 I Cs-137+D , milk/livestock-intake ratio, (pCi/L)/(pCi/d) 8.OOOE-03 8.000E-03 l RTF( 2,3)

D-34 D-34 H 11-3 , plant/soil concentration ratio, dimensionless l 4.800E+00 4.8OOE+00 l RTF( 3,1)

D-34 5 1H-3 , beef/livestock-intake ratio, (pCi/kg)/(pCi/d) l 1.200E-02 1.200E-02 l RTF( 3,2)

D-34 H 11-3 , milk/liveatock-intake ratio, (pCi/L)/(pCi/d) l 1.000E-02 1.OOOE-02 l RTF( 3,3)

D-5 l Bioaccumulation factors, fresh water, L/kg:

I.

D-5 l Co-60 , fish l 3.000E+02 3.OOOE+02 l BIOFAC( 1,1)

D-5 l Co-60 , crustacea and mollusks l 2.000E+02 2.000E+02 l BIOFAC( 1,2)

D-5 D-5 Cs-137+D , fish l 2.OOOE+03 2.OOOE+03 l BIOFACC 2,1)

D-5 Cs-137+D , crustacea and mollusks l1.000E+02 1.000E+02 lBIOFAC( 2,21 D-5 .I 1.

D-5 I H-3 , fish l 1.000E+00 1.OOOE+00 l BIOFACI 3,1)

D-5 I H-3 , crustacea and mollusks l 1.000E+00 1.000E+00 l BIOFAC( 3,2)

9^.4 L- "a

>itiL - v.. year u F/Zi/ZUU4 20:02 Page l Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Site-Specific Parameter Summary I User Used by RESRAD I Parameter Menu I Parameter I Input IF Default I (If different from user input) I Name

.1

I R011 I Area of contaminated zone (m**2) I3.965E+03 1.OOOE+04 '1 ___ I l AREA .A R011 I Thickness of contaminated zone (m) I 3.710E+00 2.000E+00 I --- .1 THICKO Roll I Length parallel to aquifer flow (m) not used 1.000+02 I -. I LCZPAQ R011 I Basic radiation dose limit (mrem/yr) I 2.500E+01 2.500E+01 I ___ I BRDL R011 I Time-since placement of material (yr) I O.OOOE+00 O.OOOE+00 I --- I TI Roll I Times for calculations (yr) I l.000E+00 I 1.000E+00 I I T( 2)

Roll I Times for calculations (yr) I 3.000E+00 I 3.000E+00 I

. I T( 3)

Roll I Times for calculations Cyr) I 1.OOOE+01 I 1.000E+01 I I T( 4)

Roll I Times for calculations Cyr) I 3.000E+01 I 3.000E+01 I . .I T( 5)

R011 I Times for calculations (yr) I 1.OOOE+02 I 1.000E+02 I I T( 6)

Roil I Times for calculations (yr) I 3.000E+02 I 3.000E+02 I I T( 7)

Roll I Times for calculations (yr) I l.O0OE+03 I 1.000E+03 I I T( 8)

R011 I Times for calculations (yr) I not used I 0. 000E+00 I

. I T( 9)

Roll I Times for calculations (yr) I not used I o.OOOE+00 I I T(10)

I I I I I R012 Initial principal radionuclide (pci/g): Co-60 4.150E+00 0.000E+00 1 i( 1)

R012 Initial principal radionuclide (pci/g): Cs-137 8.500E-01 0.000E+00 S1( 2)

R012 Initial principal radionuclide (pci/g): H-3 3.930E+01 0.000E+00 Sl ( 3)

R012 Concentration in groundwater (pCi/L): Co-60 not used O.00OE+00 W1( 1)

R012 Concentration in groundwater (pCi/L): Cs-137 not used 0.000E+00 I Wl( 2)

R012 Concentration in groundwater (pCi/L): H-3 not used 0.000E+00 I Wl( 3)

R013 Cover depth (m) 1.500E-01 0.000E+00 COVERO R013 Density of cover material (g/cm**3) 1.500E+00 1.500E+00 DENSCV R013 Cover depth erosion rate (m/yr) 1.000E-03 1.OOOE-03 VCV R013 Density of contaminated zone (g/cm**3) 1.500E+00 1.500E+00 DENSCZ R013 Contaminated zone erosion rate (m/yr) 1.000E-03 1.000E-03 VCZ R013 Contaminated zone total porosity 4.OOOE-01 4.00E-01 TPCZ R013 Contaminated zone field capacity 2.000E-01 2.000E-01 FCCZ R013 Contaminated zone hydraulic conductivity (m/yr) 1.000E+01 1.000E+01 HCCZ R013 Contaminated zone b parameter 5.300E+00 5.300E+00 BCZ R013 Average annual wind speed (insec) 2.OOOE+00 2.000E+00 WIND R013 Humidity in air (g/m**3) 8.OOOE+00 8.000E+00 HUMID R013 Evapotranspiration coefficient 5.OOE-01 5.000E-01 EVAPTR R013 Precipitation (m/yr) 1.000E+00 1.OOOE+00 PRECIP R013 Irrigation (m/yr) 2.000E-01 2.00E-01 RI R013 Irrigation mode overhead overhead IDITCH R013 Runoff coefficient 2.00OE-01 2.000E-01 RUNOFF R013 Watershed area for nearby stream or pond (m-*2) not used 1.000E+06 WAREA R013 Accuracy for water/soil computations not used 1.000E-03 EPS R014 Density of saturated zone (g/cm**3) not used 1.500E+00 l DENSAQ R014 Saturated zone total porosity not used 4.OOE-01 I TPSZ R014 Saturated zone effective porosity not used 2.000E-01 EPSZ R014 Saturated zone field capacity not used 1.2.000E-ol I FCSZ R014 Saturated zone hydraulic conductivity (m/yr) not used 1.000E+02 HCSZ R014 Saturated zone hydraulic gradient not used 2.000E-02 lHGWT R014 Saturated zone b parameter not used 5.300E+00 l BSZ R014 Water table drop rate (m/yr) not used 1.000E-03 VWT R014 R0l14 Well pump intake depth (m below water table) not used 1.000E+01 l DWIBWT R014 Model: Nondispersion (ND) or Mass-Balance (MB) not used NDI I MODEL

RESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:29 Page 4 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Site-Specific Parameter Summary (continued)

. I User l Used by RESRAD l Paramet er Menu I Parameter I Input l Default ((If different-from user inp .It) l Name I

R014 I Well pumping rate (m**3/yr) I 1ncot usedl 2.500E+02 l IUW

I 1 RO1S I Number of unsaturated zone strata 1 ;ncot used l II

IlNSN R015 I Unsat. zone 1, thickness (i) I ncot used l 4.OOOE+00 l i H(1)

RO1S I *Unsat. zone 1, soil density (g/cm**3) ncot used l 1.500SE+00 I DENSUZ(l 1}

R015 I Unsat. zone 1, total porosity I ncAtused l 4.000E-01 l TPUZ(1)

R015 I Unsat. zone 1, effective porosity I ncot used l 2.000E-01 l l EPUZ(1)

R015 I Unsat. zone 1, field capacity I ncot used l 2.000E-01 l l FCUZ(1)

ROls I Unsat. zone 1, soil-specific b parameter I nc 5.300E+00 l l 3UZ(1)

R015 I Unsat. zone 1, hydraulic conductivity (im l/Y 1r) I ncot used l l.OOOE+01 l I HCUZ(l)

I R016 Distribution coefficients for Co-60 I R016 Contaminated zone (cm**3/g) I 1 .OOOE+03 l l.OOOE+03 l l DCNUCC( 1).

R016 Unsaturated zone 1 (cm**3/g)

I niot used l 1.OOOE+03 l l DCNUCU( 1,1)

R016 Saturated zone (ci**3/g)

I niot used l 1.OOOE+03 l ___

l DCNUCS( 1)

R016 Leach rate (/yr) I 0 .OOOE+00 l O.OOOE+0O l 8.983E-05 l ALEACH( 1)

R016 Solubility constant I 0 .OOOE+0O l O.OOOE+00 l not used l SOLUBK( 1)

I R016 Distribution coefficients for Cs-137 I

R016 Contaminated zone (cm**3/g) I 1 .OO0E+03 l 1.OOOE+03 l ___

I DCNUCC( 2)

R016 Unsaturated zone 1 (cm**3/g) n,ot used l.OOOE+03 I l I DCNUCU( 2,1)

R016 Saturated zone (cmn**3/g)

I n~ot used l l.OOOE+03 l l DCNUCS( 2)

R016 Leach rate (/yr) 0 I.OOOd+OO l O.OOOE+00 l I .000t+00 8.983E-05 I ALEACH( 2)

R016 Solubility constant 0 MOOOE+00 l O.OOOE+00 I I not used I SOLUBK( 2)

I R016 Distribution coefficients for H-3 I R016 Contaminated zone (cm**3/g)

.00 .0 I I 0 .OOOE+00 O.OOOE+OO0 ___

DCNUCC( 3)

R016 Unsaturated zone 1 (cm-*3/g)

I n ot used l O.OOOE+0O l l DCNUCU( 3, 1)

R016 Saturated zone Ccm**3/g)

I n ot used l O.OOOE+00 l l DCNUCS( 3)

R016 Leach rate (/yr) I 0 .OOOE+00 l 0.OOOE+00 l 4.200E-01 l ALEACH( 3)

R016 Solubility constant I 0 .OOOE+00 l O.OOOE+l00 not used I SOLUBK( 3)

I R017 Inhalation rate (m**3/yr) I 8 .400E+03 l 8.400E+03 l 0s a l INHALR R017 Mass loading for inhalation (g/m**3)

I 1 .OOOE-04 l 1.OOOE-04 l ___

l MLINH R017 Exposure duration 3 .000E+01 l 3.000E+01 l ___

I lED R017 Shielding factor, inhalation 4 .0005-01 l 4.000E-1 l ___

I l SHF3 R017 Shielding factor, external gamma 7 .000E-01 I 7.0000E-O1 I ___

l SHF1 R017 Fraction of time spent indoors I 0 .OOOE+00 5.000E-01 l l FIND R017 Fraction of time spent outdoors (on site) 2 .EOOE-02 2.500E-0l l I lFOTD R017 Shape factor flag, external gamma 1 I .OOOE+00 l 1.OOOE+00 l >0 shows circular AREA. l FS

^&orw,Jvertoln e.Z 2 +/-Limit o - u.b year 07/27/2004 09:29 Page 5 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Site-Specific Parameter Summary (continued)

Il User I I Used by RESRAD I Parameter Parameter Input I Default I (If different from user input) I Name R017 I Radii of shape factor array (used if FS - -1): I. I R017 l Outer annular radius.(m), ring 1: I not used I 5.OOOE+01 I ___ l RAD SHAPEC 1)

R017 l Outer annular radius (m), ring 2: I not used l 7.071E+01 l ___

l RAD SHAPEC 2)

R017 l Outer annular radius (m), ring 3: I not used l 0.O00E+00 l l RADSHAPE(

___ 3)

R017 l Outer annular radius (m), ring 4: I not used l 0.OOOE+00 l l RAD SHAPE( 4)

R017 l Outer annular radius {m), ring 5: I not used l 0.OOOE+00 l ___

l RAD_SHAPE( 5)

R017 l Outer annular radius (m), ring 6: I not used l 0.OOOE+00 l ___

l RADSHAPEC 6)

R017 l Outer annular radius (m), ring 7: I not used l 0.OOOE+00 l l RADSHAPE( 7)

R017 l Outer annular radius (m), ring 8: I not used l 0.OOOE+00 l l RAD SHAPEC 8)

R017 l Outer annular radius (m), ring 9: I not used l 0.OOOE+00 l l RAD SHAPE( 9)

R017 l Outer annular radius m), ring 10: I not used l 0.OOOE+00 l ___

l RAD_SHAPEC10)

R017 l Outer annular radius {m), ring 11: I not used l 0.OOOE+00 l l RADSHAPE(l)

R017 l Outer annular radius (m), ring 12: I not used l 0.OOOE+00 l l RAD SHAPE(12)

I Fractions of annular areas within AREA:

R017 l Ring I not used l 1.OOOE+00 l l FRACAC 1)

R017 l Ring 2 not used l 2.732E-01 l FRACA( 2)

R017 l Ring 3 not used l 0.000E+00 l l FRACAC 3)

R017 l Ring 4 not used l O.OOOE+00 l l FRACA( 4)

R017 l Ring 5 not used l O.OOOE+00 l l FRACAC 5)

R017 l Ring 6 not used l O.OOOE+00 l l FRACA( 6)

R017 l Ring 7 not used l O. OOE+00 lIFRACA( 7)

R017 l Ring 8 not used l O.OOOE+00 l l FRACAC 8)

R017 l Ring 9 not used l 0.OOOE+00 l FRACA( 9)

R017 l Ring 10 not used l 0.OOOE+00 l I FRACA10)

R017 l Ring 11 not used l 0.OOOE+00 P017 l l l FRACA(ll)

Ring 12 not used l .000E+00l l FRACA(12)

P018 l I.

R018 l Fruits, vegetables and grain consumption (kg/yr) not used l 1.600E+02 l l DIET(l)

Leafy vegetable consumption (kg/yr) not used l l.400E+01 l P018* l l DIET(2)

Milk consumption (L/yr) not used l 9.200E+01 l P018 l l DIETC 3)

Meat and poultry consumption (kg/yr) not used ! 6.300E+01 l P018 l l DIETC4)

Fish consumption (kg/yr) not used I 5.400E+00 l P018 l l DIET(5)

Other seafood consumption (kg/yr) not used I 9.000E-01 l l DIET(6)

Soil ingestion rate (g/yr) not used I 3.650E+01 l P018 l l SOIL Drinking water intake (L/yr) not used I 5.100E+02 l l DWI Contamination fraction of drinking water not used I 1.000E+00 l P018 l Contamination fraction of household water not used I 1.OOOE+00 l P018 l l FHHW Contamination fraction of livestock water not used I 1.OOOE+00 l lFLW Contamination fraction of irrigation water not used I 1.000E+00 l l FIRW R018 l Contamination fraction of aquatic food not used I 5.OOOE-01 l l FR9 R018 l Contamination fraction of plant food not used 1-1 l l FPLAN4T R019 l Contamination fraction of meat not used I I-1 1 l FMEAT Contamination fraction of milk not used 1-1 . I l FMILK I. 1 Livestock fodder intake for meat (kg/day) not used I 6.800E+O l l LFI5 R0198 Livestock fodder intake for milk (kg/day) not used I 5.500E+01 l l LFI6 R0198 Livestock water intake for meat (L/day) not used I 5.000E+01 l l LWI5 R019 I Livestock water intake for milk (L/day) not used 1 l.600E+02 l l LWI6 P019 R019 I Livestock soil intake (kg/day) not used I 5.OOOE-01 l - l LSI Mass loading for foliar deposition (g/m*3) not used l 1.OOOE-04 l l MLFD

crxubr version o.zi *r Limit - U.: year U1/27/2004 09:29 Page 6 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Site-Specific Parameter Summary (continued)

User I . I Used by RESRAD Parameter Menu I Parameter .1 Input I Default (If different from user input) Name I

R019 I Depth of soil mixing layer (im) I1.50 OE-01 1.500E-01 l __-

DM R019 I Depth of roots (m) I not used 9.OOOE-01 l ___

DROOT R019 I Drinking water fraction from ground water I not used 1.OOOE+00 l ___

FGWDW R019 I Household water fraction from ground water not used l.OOOE+00 l ___

FGWHH R019 I Livestock water fraction from ground water not used l.OOOE+00 l FGWLW R019 I Irrigation fraction from ground water not used l.OOOE+00 l IYFGWIR R19B Wet weight crop yield for Non-Leafy (kg/m**2) not used 7.OOOE-01 l YV(1)

R19B Wet weight crop yield for Leafy (kg/min2) Inot. used 1.500E+00 l R19B Wet weight crop yield for Fodder (kg/m**2) not used l.lOOE+00 l (V(3)

R19B Growing Season for Non-Leafy (years) not used 1.700E-01 l rE(1)

R19B Growing Season for Leafy (years) not used 2.500E-01 l rE(2)

R19B Growing Season for Fodder (years) not used 8.000E-02 l rE(3)

R19B Translocation Factor for Non-Leafy not used 1.OOOE-01 l LSIV(l)

R19B Translocation Factor for Leafy not used l.OOOE+00 l rIV(2)

R19B Translocation Factor for Fodder not used l.OOOE+00 l R19B Dry Foliar Interception Fraction for

I!rIV(3)

Non-Leafy not used 2.500E-01 l IDRY(1)

R19B Dry Foliar Interception Fraction for- Leafy not used 2.500E-01 l RDRY(2)

R19B Dry Foliar Interception Fraction for Fodder not used 2.500E-01 l RDRY13)

R19B Wet Foliar Interception Fraction for Non-Leafy not used 2.500E-01 l RWET(1)

R19B Wet Foliar Interception Fraction for Leafy not used 2.500E-01 l RWET(2)

R19B Wet Foliar Interception Fraction for Fodder not used 2.500E-01 l RWET(3)

R19B Weathering Removal Constant for Vegetation not used 2.OOOE+01 l WLAM C14 C-12 concentration in water (9/cm**3) not used 2.OOOE-05 l .1 C12WTR C14 C-12 concentration in contaminated soil (g/g) not used 3.000E-02 l C12CZ C14 Fraction of vegetation carbon from soil not used 2.OOOE-02 l CSOIL C14 Fraction of vegetation carbon.from air not used 9.800E-01 l .II CAIR C14 C-14 evasion layer thickness in soil (m) not used 3.OOOE-01 l DMC C14 C-14 evasion flux rate from soil (1/sec) not used 7.OOOE-07 l EVSN C14 C-12 evasion flux rate from soil (i/sec) not used 1.OOOE-10 l REVSN C14 Fraction of grain in beef cattle feed not used 8.000E-01 l AVFG4 C14 Fraction of grain in milk cow feed not used 2.000E-01 l AVFG5 C14 DCF correction factor for gaseous forms of C14 not used 8.894E+01 I C02F STOR l Storage times of contaminated foodstuffs (days)

STOR l Fruits, non-leafy vegetables, and grain 1.4 00E+01 1.400E+01 l * .1 STOR_T(l)

STOR l Leafy vegetables 1.0 00E+00 1.OOOE+00 l STORT(2)

STOR l Milk 1.0 00E+00 1.OOOE+00 l STORT(3)

STOR l Meat and poultry 2.0 00E+01 2.OOOE+01 l STORT(4)

STOR l Fish 7.0 00E+00 7.000E+00 l STOR T(5)

STOR l Crustacea and mollusks 7.0 00E+00 7.OOOE+00 l STOR T(6)

STOR I Well water 1.0 00E+00 1.OOOE+00 I STOR T(7)

STOR I Surface water 1.0 OOE+00 1.000E+00 l STORT(8)

STOR l Livestock fodder 4.5 00E+01 4.500E+01 l STORT(9)

R021 l Thickness of building foundation Cm) not used 1.500E-01 l FLOOR1 R021 l Bulk density of building foundation (g/cmr*3) not used 2.400E+00 l DENSFL R021 l-Total porosity of the cover material I n6t used 4.000E-01 l TPCV R021 I Total porosity of the building foundation not used 1.000E-01 I TPFL R021 I Volumetric water content of the cover material not used 5.000E-02 PH20CV

RESRAD, Version 6.21 T4 Limit - 0.5 year 07/27/2004 09:29 Page 7 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Site-Specific Parameter Summary continued)

I User Used by RESRAD I Parameeter Menu I Parameter I Input Default l (If different from user input) I Name I I R021 I Volumetric water content of the foundation Il not used I 3.000E-02 I PH20FL R021 I Diffusion coefficient for radon gas (m/sec): I R021 .1 in cover material I not used l 2.000E-06 l I DIFCV R021 I in foundation material Inot used 3.OOOE-07 l I DIFFL R021 I in contaminated zone soil I not used l 2.OOOE-06 l I DIFCZ R021 I Radon vertical dimension of mixing (m) I not used l 2.000E+00 l I HMIX R021 I Average building air exchange rate (1/hr) I not used l 5.OOOE-0l l IREXG R021 I Height of the building (room) (m) I not used l 2.500E+00 l IHRM R021 I Building interior area factor I not used lO.OOOE+00 l I FAI R021 I Building depth below ground surface (m) I not used 1-1.000E+00 l DMFL R021 I Emanating power of Rn-222 gas lnot used I 2.500E-01 l lIEMANA (:1)

R021 I Emanating power of Rn-220 gas I not used l 1.500E-O1 I lIEMAMA C:[2)

I I l1 l I TITL I Number of graphical time points I 32 l ___ l . NPTS TITL I Maximum number of integration points for dose 17 l ___ l I LYMAX TITL I Maximum number of integration points for risk 1 257 l ___ l IKYMAX I . .

Summary of Pathway Selections Pathway l User Selection 1 -- external gamma l active 2 -- inhalation (w/o radon)] active 3 -- plant ingestion I suppressed 4 -- meat ingestion l suppressed 5 -- milk ingestion I suppressed 6 -- aquatic foods l suppressed 7 -- drinking water suppressed 8 -- soil ingestion l suppressed 9 -- radon l suppressed Find peak pathway doses l active

nu>bthu version b.21 T s Limit - 0.5 year 07/27/2004 09:29 Page 8 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Contaminated Zone Dimensions Initial Soil Concentrations, pCi/g Area: 3965.00 square meters Co-60 4.150E+00 Thickness: 3.71 meters Cs-137 8.500E-01 Cover Depth: 0.15 meters H-3 3.930E+01 Total'Dose TDOSElt), mrem/yr Basic Radiation Dose Limit - 2.500E+01 mrem/yr Total Mixture Sum M(t) - Fraction of Basic Dose Limit Received at Time Wt) t (years): 0.OOOE+00 1.000E+00. 3.OOOE+00 1.OOOE+01 3.000E+01 1.OOOE+02 3.OOOE+02 1.OOOE+03 TDOSE(t): 2.906E-01 2.586E-01 2.051E-01 9.301E-02 1.449E-02 3.617E-03 6.972E-05 6.195E-12 M(t): 1.162E-02 1.034E-02 8.205E-03 3.720E-03 5.796E-04 1.447E-04 2.789E-06 2.478E-13 Maximum TDOSE(t): 2.906E-01 mrem/yr at t - 0.OOOE+00 years

ZSRAD, Version 6.21 T4 Limit - 0.5 year 07/27/2004 09:29 Page 9 wummary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 0.0O0E+00 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Radio-

uclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

o-60 2.815E-01 0.9689 1.005E-08 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000

s-137 8.844E-03 0.0304 3.222E-10 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 4-3 0.OOOE+00 0.0000 1.877E-04 0.0006 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.00OE+00 0.0000 0.OOOE+00 0.0000 rotal 2.904E-01 0.9994 1.877E-04 0.0006 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 0.OOOE+00 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.00OE+00 0.0000 2.815E-01 0.9689 Cs-137 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 8.844E-03 0.0304 H-3 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 1.877E-04 0.0006 Total 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 2.906E-01 1.0000

Sum of all water independent and dependent pathways.

Ar.0Mww, VrtK iU O.~Z 1i2 j.miL - u.D year UI/Z//ZUU4 U9:29 Page 10 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - l.OOOE+00 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 2.497E-01 0.9657 2.683E-08 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 Cs-137 8.765E-03 0.0339 9.468E-10 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O .OOOE+OOO. 0000 O.OOOE+00 0.0000 8-3 O.OOOE+00 0.0000 9.484E-05 0.0004 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O. OOOE+0O 0. 0000 0.OOOE+00 0.0000 Total 2.585E-01 0.9996 9.487E-05 0.0004 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t)- for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - l.OOOE+00 years .

Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+0 0.0000 2.497E-01 0.9657 Cs-137 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 8.765E-03 0.0339 H-3 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 9.484E-05 0.0004 Total O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 2.586E-01 1.0000

Sum of all water independent and dependent pathways.

RESRAD, Version 6.21 T4 Limit - 0.5 year 07/27/2004 09:29 Page 11 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Total Dose Contributions TDOSEI(i,p,t) for Individual Radionuclides ji) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.000E+00 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk H Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 1.965E-01 0.9579 4.832E-08 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 Cs-137 8.610E-03 0.0420 2.111E-09 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 H-3 0.000E+00 0.0000 2.402E-05 0.0001 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 -0:OOOE+00 0.0000 Total 2.051E-01 0.9999 2.407E-05 0.0001 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 Total Dose Contributions TDOSE(ipt) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.OOOE+00 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 .1.965E-01 0.9579 Cs-137 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 8.610E-03 0.0420 H-3 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 2.402E-05 0.0001 Total 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 2.051E-01 1.0000

Sum of all water independent and dependent pathways.

KLswwA, Version b.Zl Th Limit - 0.5 year 07/27/2004 09:29 Page 12 Summary : Landfill Worker 3.71m Fill File: 2002_3.71m.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 1.000E+01 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Radio-.

Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 8.492E-02 0.9130 5.782E-08 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 Cs-137 8.087E-03 0.0869 5.385E-09 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.00OE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 H-3 0.000E+00 0.0000 -1.795E-07 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 Total 9.301E-02 1.0000 2.427E-07 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.*0000 0.OOOE+00 0.0000 Total Dose Contributions TDOSE(ipt) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 1.OOOE+01 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways' Radio-Nuclide mrem/yr fract. mrem/yr -fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 0.OOOE+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 8.492E-02 0.9130 Cs-137 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 8.087E-03 0.0869 H-3 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 1.795E-07 0.0000 Total 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 *0.000E+00 0.0000 9.301E-02 1.0000 Sum of all water independent and dependent pathways.

KtsKMA, version b.21 Th Limit - 0.5 year 07/27/2004 09:29 Page 13 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides li) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.OOOE+01 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat

Milk Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 7.728E-03 0.5333 1.209E-08 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Cs-137 6.762E-03 0.4667 9.838E-09 0.0000 0.000E+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 H-3 O.OOOE+00 0.0000 6.998E-14 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total 1.449E-02 1.0000 2.193E-08 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.000E+Ol years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 7.728E-03 0.5333 C3-137 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 6.762E-03 0.4667 H-3. O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+OO 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 6.998E-14 0.0000 Total O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+OO 0.0000 1.449E-02 1.0000 Sum of all water independent and dependent pathways.

SRAD, Version 6.21 Tv2 Limit - 0.5 year 07/27/2004 09:29 Page 14

=mary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Total Dose Contributions TDOSEli,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 1.OOOE+02 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant

Meat Milk Soil idio-3clide mrem/yr fract. mrem/y- fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

)-60 1.756E-06 0.0005 3.981E-12 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 O.000E+00 0.0000 3-137 3.615E-03 0.9995 6.392E-09 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000

-3 O.OOOE+00 0.0000 0.OOOE+OO 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.0OOE+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 3tal 3.617E-03 1.0000 6.396E-09 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways Ip)

As mrem/yr and Fraction of Total Dose At t - 1.OOOE+02 years Water Dependent Pathways Water Fi sh Radon Plant Meat Milk All Pathways*

adio-aclide mrem/yr fract. mrem/yw fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

D-60 0.OOOE+00 0.0000 0.000E+0O 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 1.756E-06 0.0005 s-137 0.000E+00 0.0000 0.000E+0O 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 3.615E-03 0.9995

-3 0.000E+00 0.0000 0.OOOE+O0 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 otal 0.OOOE+00 0.0000 0.000E+O0 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 3.617E-03 1.0000 Sum of all water independent and dependent pathways.

RESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:29 Page 15 Summary : Landfill Worker 3.71m Fill File: 2002_3.71m.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.000E+02 years Water Independent Pathways (Inhalation excludes radon) .

Ground Inhalation Radon Plant Meat Milk Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 1.163E-17 0.0000 2.206E-23 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.0000

_.OOOE+00 Cs-137 6.972E-05 1.0000 9.224E-11 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 H-3 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total 6.972E-05 1.0000 9.224E-I1 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000

Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.OOOE+02 years Water Dependent Pathways Water Fish Radon Plant 'Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 1.163E-17 0.0000 Cs-137 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 6.972E-05 1.0000 H-3. O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 6.972E-05 1.0000

Sum of all water independent and dependent pathways.

ESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:29 Page 16 ummary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mirem/yr and Fraction of Total Dose At t - l.00OE403 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Ladio-Iuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

o-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.0OOOE+00 0.0000

s-137 6.195E-12 1.0000 8.195E-18 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 .O.OOOE+00 0.0000 .O.OOOE+00 0.0000 i-3 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 rotal 6.195E-12 1.0000 8.195E-18 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides Ci) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - l.OOOE+03 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Cs-137 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 6.195E-12 1.0000 H-3 *O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total O.OOOE400 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 6.195E-12 1.0000

Sum of all water independent and dependent pathways.

RESRAD, Version 6.21 T4 Limit - 0.5 year 07/27/2004 09:29 Page 17 Summary : Landfill Worker 3.71m Fill File: 2002 3.71m.RAD Dose/Source Ratios Summed Over All Pathways Parent and Progeny Principal Radionuclide Contributions Indicated Parent Product Branch DSR(Jt) (mrem/yr)/(pCi/g)

(i) (i) Fraction* t- O.OOOE+00 l.OOOE+00 3.000E+00 1.000E+01 3.000E+01 1.000E+02 3.OOOE+02 l.OOOE+03 Co-60 Co-60 1.OOOE+00 6.784E-02 6.017E-02 4.735E-02 2.046E-02 1.862E-03 4.232E-07 2.803E-18 O.OOOE+00 Cs-137 Cs-137 l.000E+00 1.040E-02 1.031E-02 1.013E-02 9.514E-03 7.956E-03 4.254E-03 8.203E-05 7.268E-12 H-3 H-3 l.000E+00 4.775E-06 2.413E-06 6.111E-07 4.567E-09 1.7B1E-15 8.B55E-42 O.OOOE+00 O.OOOE+00

Branch Fraction is the cumulative factor for the j't principal radionuclide daughter: CUMBRFrj) - BRF(1)*BRF(2)p ... BRF(J).

The DSR includes contributions from associated (half-life S 0.5 yr) daughters.

Single Radionuclide Soil Guidelines G(i,t) in pCi/g Basic Radiation Dose Limit - 2.500E+01 mrem/yr Nuclide (i) t- O.OOOE+00 l.OOOE+00 3.000E+00 l.0O0E+01 3.000E+01 1.OOOE+02 3.000E+02 l.OOOE+03 Co-60 3.685E+02 4.155E+02 5.280E+02 1.222E+03 1.343E+04 5.907E+07 *1.131E+15 *1.131E+15 Cs-137 2.403E+03 2.424E+03 2.468E+03 2.628E+03 3.142E+03 5.877E+03 3.048E+05 3.430E+12 H-3 5.235E+06 1.036E+07 4.091E+07 5.475E+09 *9.594E+15 *9.594E+15 *9.594E+15 *9.594E+15

At specific activity limit Summed Dose/Source Ratios DSR~i,t) in (mrem/yr)/(pCi/g) and Single Radionuclide Soil Guidelines G(i,t) in pCi/g at tmin - time of minimum single radionuclide soil guideline and at tmax - time of maximum total dose - 0.000E+00 years Nuclide Initial tmin DSR(i,tmin) G(i,tminj DSR(i,tmax) G(I,tmax)

(i) (pCi/g) (years) (pCi/g) CpCi/g)

Co-60 4.150E+00 O.OOOE+00 6.784E-02 3.685E+02 6.784E-02 3.685E+02 Cs-137 8.500E-01 O.OOOE+00 1.040E-02 2.403E+03 1.040E-02 2.403E+03 H-3 3.930E+01 0.000E+00 4.775E-06 5.235E+06 4.775E-06 5.235E+06

RESRAD, Version 6.21 T' Limit - 0.5 year 07/27/2004 09:29 Page 18 Summary : Landfill Worker 3.71m Fill File: 2002_3.71m.RAD

Individual Nuclide Dose Suimed Over All Pathways Parent Nuclide and Branch Fraction Indicated Nuclide Parent BRF(i) DOSE(J,t), mrem/yr (j) (i) t- O.OOOE+00 1.OOOE+00 3.000E+00.l.OOOE+01 3.000E+01 l.000E+02 3.OOOE+02 l.000E+03 Co-60 Co-60 l.OOOE+00 2.815E-01 2.497E-01 1.965E-0l'8.492E-02 7.728E-03 1.756E-06 1.163E-17 O.OOOE+00 Cs-137 Cs-137 l.OOOE+00 8.844E-03 8.765E-03 8.610E-03 8.087E-03 6.762E-03 3.615E-03 6.972E-05 6.195E-12 H-3 H-3 l.000E+00 1.877E-04 9.484E-05 2.402E-05 1.795E-07 6.998E-14 O.OOOE+00 O.OOOE+00 O.OOOE+00 BRF(i) is the branch fraction of the parent nuclide.

Individual Nuclide Soil Concentration Parent Nuclide and Branch Fraction Indicated Nuclide Parent BRF(i) S(j,t), pCi/g (j) Ci) t- O.OOOE+00 1.OOOE+00 3.OOOE+00 1.OOOE+01 3.000E+01 1.OOOE+02 3.000E+02 1.OOOE+03 Co-60 Co-60 1.000E+00 4.150E+00 3.638E+00 2.796E+00 1.113E+00 8.009E-02 8.000E-06 2.973E-17 0.00E+00 Cs-137 Cs-137 1.OOOE+00 8.500E-01 8.305E-01 7.929E-01 6.740E-01 4.239E-01 8.358E-02 8.080E-04 7.179E-1l H-3 H-3 1.000E+00 3.930E+01 1.976E+01 4.950E+00 3.568E-02 1.268E-08 4.942E-35 O.OOOE+00 0.OOOE+00 BRF(i) is the branch fraction of the parent nuclide.

RESCALC.EXE execution time - 0.71 seconds

Attachment 5 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 RESRAD ASSESSMENT OF PUBLIC RESIDENT I FARMER DOSE (Public.rad)

September 15, 2004 18 Pages

RESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:42 Page 1 Sumnary : 3.71m Landfill Farm File: 02_3.7lFmr.PRAD L4t d gb/i FQ IeIr Table of Contents o/ 176 tj l te .3o,,-

Part I: Mixture Sums and Single Radionuclide Guidelines Dose Conversion Factor (and Related) Parameter Summary ... 2 Site-Specific Parameter Summary ..... ..................... 3 Summary of Pathway Selections ...... ...................... 7 Contaminated Zone and Total Dose Summary .... ............. 8 Total Dose Components Time - 0.OOOE+00 ....... ............................. 9 Time - 1.000E+00 ......... ............................ 10 Time - 3.000E+00 ....... ............................. 11 Time - 1.OOOE+01 ............... 12 Time - 3.000E+01 ........ ............................ 13 Time - 5.000E+01 ............... 14 Time - 3.000E+02 ....... ............................. 15 Time - 1.000E+03 ....... ............................. 16 Dose/Source Ratios Summed Over All Pathways .... ..........17 Single Radionuclide Soil Guidelines ..... ................. 17 Dose Per Nuclide Summed Over All Pathways .... ............18 Soil Concentration Per Nuclide ...... ..................... 18

RESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:42 Page 2 Summary : 3.71m Landfill Farm File: 02_3.7iFmr.RAD Dose Conversion Factor (and Related) Parameter Summary File: FGR 13 Morbidity Current I I Parameter Menu I Parameter Value I Default I Name B-1 I Dose conversion factors for inhalation, mrem/pCi:

B-1 I Co-60 2.190E-04 2.190E-04 l DCF2( 1)

B-1 I Cs-137+D 3.190E-05 I3.190E-05 IlDCF2( 2)

B-1 I H-3 6.400E-08 I 6.400E-08 I DCF2( 3)

I D-1 I Dose conversion factors for ingestion, mrem/pCi:

D-1 I Co-60 2.690E-05 l 2.690E-05 I DCF3( 1)

D-13 Cs-137+D 5.OOOE-05 I 5.000E-05 I DCF3( 2)

D-3 I H-3 6.400E-08 I 6.400E-08 I DCF3( 3)

I D-34 I Food transfer factors:

I.

D-34 I Co-60 ,plant/aoil concentration ratio, dimensionless 8.000E-02 l 8.000E-02 I RTF( 1,1)

D-34 I Co-60 ,beef/livestock-intake ratio, (pCi/kg)/(pCi/d) 2.000E-02 l 2.000E-02 I RTF( 1,2)

D-34 I Co-60 ,milk/livestock-intake ratio, (pCi/L)/(pCi/d) 2.000E-03 2.000E-03 I RTF( 1,3)

D-34 I 1 D-34 I Cs-137+D ,plant/soil concentration ratio, dimensionless 4.000E-02 I 4.OOOE-02 I RTF( 2,1)

D-34 I Cs-137+D ,beef/livestock-intake ratio, (pCi/kg)/(pCi/d) 3.000E-02 l 3.000E-02 I RTF( 2,2)

D-34I Cs-137+D ,milk/livestock-intake ratio, (pCi/L)/(pCi/d) 8.000E-03 l 8.000E-03 I RTF( 2,3)

D-34I .I D-34 I H-3 , plant/soil concentration ratio, dimensionless 4.800E+00 I 4.800E+00 I RTF( 3,1)

D-34 I H-3 , beef/livestock-intake ratio, (pCi/kg)/(pCi/d) 1.200E-02 I 1.200E-02 I RTF( 3,2)

D-34 I H-3 , milk/livestock-intake ratio, (pCi/L)/(pCi/d) 1.000E-02 l 1.000E-02 I RTF( 3,3)

I D-5 I Bioaccumulation factors, fresh water, L/kg:

D-5 I Co-60 , fish 3.000E+02 l 3.OOOE+02 I BIOFAC( 1 t1)

D-5 I Co-60 , crustacea and mollusks 2.000E+02 l 2.000E+02 I BIOFAC( 1 ,2)

D-5 I D-5 I Cs-137+D , fish . 2.000E+03 2.000E+03 l BIOFAC( 2 ,1)

D-5 lI Cs-137+D , crustacea and mollusks 1.000E+02 1.OOOE+02 l BIOFAC( 2 ,2)

D-5 I D-5 I H-3 , fish 1.000E+00 1.OOOE+00 l BIOFAC( 3,1)

D-5 I H-3 I

, crustacea and mollusks 1.000E+00 1.000E+00 ! BIOFAC( 3,2)

V o.Z

LiuI *.M Limit - u.s year U7/27/2004 09:42 Page 3 Summary : 3.71m Landfill Farm File: 02 3.71Fmr.RAD Site-Specific Parameter Summary I l User I I Used by RESRAD l Parameter Menu l Parameter l Input - Default ((If different from user input) l Name I~~~ 11 AREA ROll Area of contaminated zone (m**2) l 3.965E+03 I 1.OOOE+04 I. lAMEA ROll Thickness of contaminated zone (m) l 3.710E+OO l 2.OOOE+OO I l THICKO ROll Length parallel to aquifer flow (m) l l.000E+02 l l.OOOE+02 I l LCZPAQ ROll Basic radiation dose limit (mrem/yr) l 2.500E+O1 l 2.500E+Ol I l BRDL ROll Time since placement of material (yr) l O.OOOE+OO l O.OOOE+OO I l TI ROll Times for calculations (yr) l l.OOOE+OO l 1.OOOE+OO I T( 2)

ROll Times for calculations (yr) l 3.OOOE+OO l 3.OOOE+OO I l T( 3)

ROll Times for calculations (yr) l l.OOOE+Ol l l.OOOE+Ol I l T( 4)

ROll Times for calculations (yr) l 3.OOOE+O1 l 3.OOOE+Ol I l T( 5)

ROll Times for calculations (yr) l 5.000E+Ol l 1.OOOE+02 I l T( 6)

ROll Times for calculations (yr) 3.OOOE+02 l 3.OOOE+02 I l T( 7)

ROll Times for calculations (yr) l l.OOOE+03 l 1. OOOE+03 I l T( 8)

ROll Times for calculations Cyr) not used l 0. OOOE+OO I T( 9)

ROll Times for calculations (yr) not used l O.OOOE+OO I l T(10)

I 1.:

R012 Initial principal radionuclide l 4.150E+OO l O.OOOE+OO (pci/g): Co-60 I. 1 Sl( 1)

R012 Initial principal radionuclide (pCi/g3: Cs-137 l 8.500E-O1 I 0. OOOE+OO I Sl( 2)

R012 Initial principal radionuclide (pCi/g) - Sl( 3)

H-3 l 3.930E+O1 O.OOOE+00 I R012 Concentration in groundwater (pCi/L): Co-60 l not used l O.OOOE+OO I Wl( 1)

R012 Concentration in groundwater (pCi/L): Cs-137 l not used l O.OOOE+OO I W1( 2)

R012 Concentration in groundwater (pCi/Ll: H-3 l not used l O.OOOE+OO Wl( 3)

I . . I R013 Cover depth (m) l 1.220E+OO l O.OOOE+OO l l COVERO R013 Density of cover material (g/cm**3) l l.500E+OO l.l.500E+OO l l DENSCV R013 Cover depth erosion rate (m/yr) l l.OOOE-03 l l.OOOE-03 l I VCV R013 Density of contaminated zone (g/cm**3) l l.500E+OO l l.500E+OO ___

l DENSCZ R013 Contaminated zone erosion rate (m/yr) 1l.OOOE-03 l 1.OOOE-03 l ___

IVCZ R013 Contaminated zone-total porosity l 4.000E-O1 l 4.OOE-O1 l l TPCZ R013 Contaminated zone field capacity 2.OOOE-Ol l 2.OOOE-O1 l l FCCZ R013 Contaminated zone hydraulic conductivity (m/yr) l l.OOOE+Ol l l.OOOE+Ol l l HCCZ R013 Contaminated zone b parameter l 5.300E+OO l 5.300E+OO l l BCZ R013 Average annual wind speed (m/sec) l 2.OOOE+OO l 2.OOOE+OO l l WIND R013 Humidity in air (g/m**3) l 8.000E+OO l 8.OOOE+OO l l HUMID R013 Evapotranspiration coefficient l 5.OOOE-O1 l 5.OOOE-O1 l l EVAPTR R013 Precipitation (m/yr) l l.OOOE+OO l l.OOOE+OO l l PaECIP R013 Irrigation (m/yr) l 2.OOOE-O1 l 2.OOOE-O1 l l RI

_W__

R013 Irrigation mode l overhead l overhead l l IDITCH R013 Runoff coefficient 2.OOOE-Ol l 2.OOOE-O1 l l RUNOFF R013 Watershed area for nearby stream or pond (m**2) lOOOE+06

1. l l.OOOE+06 l l WAREA R013 Accuracy for water/soil computations l l;OOOE-03 l l.OOOE-03 l l EPS I . I R014 Density of saturated zone (g/cm**3) l l.500E+OO l 1.500E+OO l l DENSAQ R014 Saturated zone total porosity 4.OOOE-O1 l 4.000E-O1 l l TPSZ R014 Saturated zone effective porosity l 2.OOOE-O1 l 2.OOOE-O1 l l EPSZ R014 Saturated zone field capacity l 2.OOOE-O1 l 2.OOOE-O1 l lFCSZ R014 Saturated zone hydraulic conductivity (m/yr) l l.OOOE+02l l.OOOE+02 l l HCSZ 1014 Saturated zone hydraulic gradient l 2.OOOE-02 2.OOOE-02 l lHGWT 014 Saturated zone b parameter l 5.300E+OO 5.300E+OO l l BSZ 1014 Water table drop rate (m/yr) l l.OOOE-03 l l.OOOE-03 l IWT 014 Well pump intake depth (m below water table) l l.OOOE+Ol l.OOOE+Ol l l DWIBWT 1014 Model: Nondispersion (ND) or Mass-Balance (MB) l ND lND I l MODEL

RESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:42 Page 4 Summary : 3.71m Landfill Farm File: 02 3.71F'mr.RAD Site-Specific Parameter Summary (continued)

User . I Used by RESRAD I Parameter Menu l Parameter Input l (IIfdifferent -from user input)

Default I Name l -

I .

R014 Well pumping rate (m**3?yr) 2.500E+02 l 2.500E+02 l IUW '

I. I R015 Number of unsaturated zone strata 1 1i1 I *IS lNS R015 l Unsat. zone 1, thickness Cm) 4.OOOE+00 4.000E+00 l l H(1)

R015 Unsat. zone 1, soil density (g/cm**3) 1.500E+00 l 1.500E+00 l l DENSUZ(1 R015 l Unsat. zone 1, total porosity 4.OOOE-01 l 4.000E-01 l l TPUZ(1)

R015 Unsat. zone 1, effective porosity 2.OOOE-01 l 2.OOOE-01 l l EPUZ(1)

R015 Unsat. zone 1, field capacity 2.000E-01 2.000E-01 l l FCUZ(1)

R015 Unsat. zone 1, soil-specific b parameter 5.300E+00 l 5.300E+00 l l BUZ(1)

ROi5 l Unsat. zone 1, hydraulic conductivity (m/yr) 1.OOOE+01 l l.OOOE+0l l l HCUZ l)

R016 Distribution coefficients for Co-60 R016 l Contaminated zone (cm**3/g) 1.000E+03 l 1.000E+03 l DCNUCC(

R016 Unsaturated zone 1 (cn**3/g) 1.OOOE+03 l 1.000E+03 I I DCNUCU( 1,1)

I)

R016 l Saturated zone (cm**3/g) l.OOOE+03 l 1.000E+03 l I DCNUCS( 1)

R016 l Leach rate (/yr) O.OOOE+00 O.OOOE+00 l 8. 983-05 l ALEACH( 1)

R016- - Solubility constant O.OOOE+00 l[0.000E+00 not used '1) l SOLUBK1(

I . I I.

R016 Distribution coefficients for Cs-137 I I I .

R016 l Contaminated zone (cm**3/g) l.OOOE+031 1.000E+03 l I DCNUCC( 2)

R016 Unsaturated zone 1 (cm**3/g) 1.OOOE+03 l 1.OOOE+03 l I DCNUCU( 2,1)

R016 l Saturated zone (cm**3/g) 1.000E+03 I1.000E+03 I DCNUCS( 2)

R016 Leach rate (/yr) 0.OOOE+00 l l.OOOE+00 l 8. 983E-05 I ALEACH( 2)

R016 Solubility constant o.oooE+00 0.000E+00 not-used l SOLUBK( 2)

O.OOOE+OO0 I O.OOOE+OO0 I R016 Distribution coefficients for H-3 O.'OOOE+OO0 I O.OOOE+OO0 I R016 Contaminated zone (cm**3/g) O.OOOE+00 l O.OOOE+00 I DCNUCC( 3)

R016 Unsaturated zone 1 (cm**3/g) O.OOOE+00 O.OOOE+00 l I DCNUCU 3,1)

R016 Saturated zone (cm**3/g)

- DCNUCS( 3)

R016 Leach rate (/yr) 4. 200E-01 l ALEACH( 3)

R016 Solubility constant O.OOOE+00 O.OOOE+OO l not used l SOLUBK( 31.

Inhalation rate (m**3/yr) 8.400E+03 l 8.400E+03 l l INHALR Mass loading for inhalation (g/m**3) 1.OOOE-04 l 1.OOOE-04 l l MLINH Exposure duration 3.000E+01 l 3.000E+01 l l ED Shielding factor, inhalation 4.000E-01 l 4.000E-01 l l SHF3 Shielding factor, external gamma 7.000E-01 l 7.000E-01 l l SHF1 Fraction of time spent indoors 5.000E-01 l 5.000E-01 l l FIND Fraction of time spent outdoors (on site) 2.580E-01 l 2.500E-01 l lFOTD Shape factor flag, external gamma 1.000E+00 l 1.400E+00 l >0 showis circular AREA'. lFS

RESRAD, Version 6.21 T4 Limit - 0.5 year 07/27/2004 09:42 Page 5 Su=mary : 3.71m Landfill Farm File: 02 3.7lFmr.RAD Site-Specific Parameter Suma=ry (continued)

User I Used by RESRAI D l Parameter Menu I Parameter I Input Default I CIf different from us(er input) l Name R017 l Radii of shape factor array (used if FS - - 1): 1 .I R017 l Outer annular radius m), ring 1: not used 5.OOOE+01 l RAD SHAPE( 1)

R017. l Outer annular radius (m), ring 2: not used 7.071E+01 l l RAD SHAPEC 2)I R017 l Outer annular radius m), ring 3: l not used 0.000E+00 l l RAD SHAPE( 3ji.

R017 l Outer annular radius (m), ring 4: not used 0.OOOE+00 l l RADSHAPEC 4:I R017 Outer annular radius Im), ring 5: l not used l 0.000E+00 l l RADSHAPEC 5SI R017 l Outer annular radius i), ring 6: not used l O.OOOE+00 l l RADSHAPE( 6GI R017 Outer annular radius Im), ring 7: l not used l 0.000E+00 I l RADSHAPEC 7]I R017 l Outer annular radius m), ring 8: l not used 0.000E+00 l l RAD SHAPEC 8BI RO17 l Outer annular radius (Im), ring 9: l not used l 0.OOOE+0 l l RAD SHAPE( 9 R017 l Outer annular radius m), ring 10: l not used l 0.000E+00 l I RADSHAPE10 R017 l Outer annular radius m), ring 11: not used l 0.000E+00 l l RAD SHAPE121 R017 l Outer annular radius Cm), ring 12: I not used l 0.000E+00 l RADSHAPEC12

1. 1 R017 Fractions of annular areas within AREA:

I I ' .1 R017 Ring 1 not used 1.OOOE+00 ! l FRACAC 1)

R017 Ring 2 l not used l 2.732E-01 l l FRACA( 2)

R017 Ring 3 not used l 0.000E+00 l l FRACA( 3)

R017 Ring 4 not used l 0.000E+00 l l FRACA( 4).

R017 Ring S l not used l O.OOOE+00 l l VRACA( 5)

R017 Ring 6 l not used l 0.000E+00 l l FRACA( 6)

R017 Ring 7 not used l 0.000E+00 l i FRACA( 7)

R017 Ring 8 I not used l 0.000E+00 l l FRACAC 8)

R017 Ring 9 not used l O.OOOE+00 l l FRACAC 9)

R017 Ring 10 not used l 0.000E+00 l l FRACA10)

Rol? Ring 11 not used l 0.000E+00 l l FRACA(li)

R017 Ring 12 not used l 0.000E+00 l l FRACA(12)

I I Ro01 Fruits, vegetables and grain consumption (k:g/yr) l 1.600E+02 l 1.600E+02 l _ __ l DIET(l)

R018 Leafy vegetable. consumption Ckg/yr) l 1.400E+01 l 1.400E+01 l ___

l DIET(2)

R018 Milk consumption (L/yr) l 9.200E+01 l 9.200E+01 l _ __

l DIETC3)

R018 Meat and poultry consumption Ckg/yr) l 6.300E+01 l 6.300E+01 l ___

l DIET(4)

Role Fish consumption (kg/yr) l 5.400E+00 l 5.400E+00 l ___

l DIETC5)

R018 Other seafood consumption Ckg/yr) l 9.OOOE-01 l 9.000E-01 l ___

l DIET(6)

RO18 Soil Ingestion rate (g/yr) l 3.650E+01 l 3.650E+01 l ___

l SOIL ROl Drinking water intake (L/yr) l 5.100E+02 l 5.100E+02 l IDWI R018 Contaminatlon fraction of drinking water l 1.000E+00 l 1.000E+00 l _ __

l FDW R018 Contamination fraction of household water not used l 1.000E+00 l ___

lFHHW Role Contamination fraction of livestock water l l.O00E+oo l 1.000E+00 l lFLW R018 Contamination fraction of irrigation water l 1.000E+00 l 1.000E+00 I FIRW R018 Contamination fraction of aquatic food l 5.000E-01 l 5;OOOE-01 l l FR9 R018 Contamination fraction of plant food I-1 0.500E+00 l FPLANT ROle Contamination fraction of meat I-1 1-1 . O.i98E+00 l FMEAT R018 Contamination fraction of milk I- .1 1-1 . I 0.198E+00 l FMILK I

R019 I Livestock fodder intake for meat (kg/day)

I. 6.800E+01 l 6.800E+01 l l LFI5 R019 I Livestock fodder intake for milk (kg/day)

I 5.500E+01 l 5.500E+01l l LFI6 R019 I Livestock water intake for meat CL/day) I 5. 000E+01 l 5.000E+01 l LWI5 R019 I Livestock water intake for milk CL/day) I 1. 600E+02 l 1.600E+02 l l LWI6 R019 I Livestock soil intake (kg/day)

I 5.000E-01 l 5.000E-01 l LSI R019 I Mass loading for foliar deposition tg/m**3)

I 1.000E-04 l 1.000E-04 l l MLFD

BaOnsW, vwraiun o.Z1 *xr Limit - u.D year U1/Z//2UU4 U9:42 Page 6 Summary : 3.71m Landfill Farm File: 02_3.71Fmr.RAD Site-Specific Parameter Summary (continued) l User l l Used by RESRAD I Parameter Menu I Parameter l Input l Default (If different from user input) l Name

_ I R019 Depth of soil mixing layer (im) l 1.500E-01 l 1.500E-01 l lIDM R019 l Depth of roots (m) l 1.400E+00 l 9.000E-01 l lDROOT R019 l Drinking water fraction from ground water l 1.OOOE+00 l 1.000E+00 l l FGWDW R019 l Household water fraction from ground water l not used l 1.000E+00 l l FGWHH R019 I Livestock water fraction from ground water l 1.000E+00 l 1.000E+00 l l FGWLW R019 I Irrigation fraction from ground water l 1.000E+00 l 1.000E+00 l l FGWIR R19B IWet weight crop yield for Non-Leafy Ckg/m**2) l 7.OOOE-01 l 7.000E-01 l I YV(l)

R19B l Wet weight crop yield for Leafafy Ckg/m**2) l 1.500E+00 l 1.500E+00 l YV(2)

R19B l Wet weight crop yield for Fodder (kg/m**2) l 1.100E+00 l 1.100E+00 l lYV(3)

R19B Growing Season for Non-Leafy (years) l 1.700E-01 l 1.700E-01 l l TS(1)

R19B l Growing Season for Leafy (years) l 2.500E-01 l 2.500E-01l l TE(2)

R19B l Growing Season for Fodder (years) l 8.OOOE-02 l 8.000E-02 l l TE(3)

R19B l Translocation Factor for Non-Leafy l 1.000E-0 l 1.000E-01 l l TIV(l)

R19B l Translocation Factor for Leafy' l 1.000E+00 l 1.OOOE+00 l l TIV(2)

R19B l Translocation Factor for Fodder l 1.000E+00 l 1.OOOE+00 l l TIV(3)

R19B l Dry Foliar Interception Fraction for Non-Leafy l 2.500E-01 l 2.500E-01 l lRDRYM1 R19B l Dry Foliar Interception Fraction for. Leafy l 2.500E-01 l 2.500E-01 l l RDRY(2)

R19B Dry Foliar Interception Fraction for Fodder 2.500E-01 l 2.500E-01 l l RDRY(3)

R19B l Wet Foliar Interception Fraction for Non-Leafy l 2.500E-01 l 2.500E-01 l I.RWET(1)

R19B l Wet Foliar Interception Fraction for Leafy l 2.500E-01 l 2.500E-01 l I RWET(2)

R19B Wet Foliar Interception Fraction for Fodder l 2.500E-01 l 2.500E-01 l I RWET(3)

R19B l Weathering Removal Constant for Vegetation l 2.OOOE+01 l 2.000E+01 l I WLAM I. *I C14 } C-12 concentration in water (g/cm**3) l not used l 2.000E-05 l l C12WTR C14 l C-12 concentration in contaminated soil (g/g) not used l 3.OOOE-02 l C12CZ C14 l Fraction of vegetation carbon from soil l not used l 2.OOOE-02 l l CSOIL C14 l Fraction of vegetation carbon from air l not used l 9.800E-01 l lCAIR C14 C-14 evasion layer thickness in soil (Im) l not used l 3.000E-01 l l DMC C14 C-14 evasion flux rate from soil (1/sec) l not used l 7.000E-07 l l EVSN C14 C-12 evasion flux rate from soil (1/sec) l not used l 1.OOOE-10 l l REVSN C14 l Fraction of grain in beef cattle feed not used l 8.000E-01 l l AVFG4 C14 l Fraction of grain in milk cow feed l not used l 2.000E-01 l l AVFG5 C14 l DCF correction factor for gaseous forms of C14 l not used l 8.894E+01 l lC02F I.

STOR l Storage times of contaminated foodstuffs (days): I I STORP l Fruits, non-leafy vegetables, and grain l 1.400E+01 l 1.400E+01 l l STOR T(1)

STOR l Leafy vegetables l 1.000E+00 l 1.000E+00 l l STORPT(2)

STOR l Milk l 1.OOOE+00 l 1.000E+00 l l STOR T(3)

STOR l Meat and poultry l2.060E+01l 2.OOOE+01 l l STORT(4)

STOR l Fish l 7.OOOE+00 l 7.OOOE+00 I l STORT.(5)

STOR l Crustacea and mollusks l 7.OOOE+00 l 7.000E+0o l l STORPT(6)

STOR l Well water l 1.000E+00 l 1.000E+00 I l STORPT(7)

STOR l Surface water l 1.000E+00 l 1.000E+00 l l STOR T(S)

STOR l Livestock fodder l 4.500E+01 4.500E401 l STORT(9) l R021 I Thickness of building foundation (m) not used l 1.500E-01 l l FLOORI R021 i Bulk density of building foundation (g/cm**3) not used l 2.400E400 l lDENSFL R021 IlTotal porosity of the cover material not used l 4.OOOE-01 l l TPCV R021 I Total porosity of the building foundation l not used l 1.OOOE-01 l lTPFL R021 I Volumetric water content of the cover material lnot used l 5.000E-02 l l PH20CV

version a.zi vivu 1.i Limit - u.3 year 07/27/2004 09:42 Page 7 Summary 3.71m Landfill Farm File: 02_3.71Fmr.RAD Site-Specific Parameter Summary (continued) l User Used by RESRAD l Parameter Menu l Parameter l Input - Default (If different from user input) l Name I .. ' 1 I R021 l Volumetric water content of the foundation l not used I 3.000E-02 I --- l PH20FL R021 l Diffusion coefficient for radon gas (m/sec): l l l l R021 l in cover material l not used l 2.000E-06 l --- l DIFCV R021 l in foundation material l not used i 3.000E-07 l --- l DIFFL R021 l in contaminated zone soil l not used l 2.000E-06 l -- l DIFCZ R021 l Radon vertical dimension of mixing {m) not used l 2.OOOE+00 l --- l HMIX R021 l Average building air exchange rate (1/hr) l not used l 5.000E-01 l --- l REXG R021 l Height of the building (room) {m) l not-used l 2.500E+00 l --- l HRM R021 l Building interior area factor l not used I O.OOOE+00 l --- l FAI R021 l Building depth below ground surface (m) I not used I-l.000E+00 I --- l DMFL R021 l Emanating power of Rn-222 gas l not used l 2.500E-01 l --- l EMANA(l)

R021 l Emanating power of Rn-220 gas l not used l 1.500E-0l l --- l EMANA(2)

I. .I. 1I1 'I1 TITL l Number of graphical time points l 32 1 _ l NPTS TITL l Maximum number of integration points for dose l 17 1 --- l .LYMAX TITL l Maximum number of integration points for risk l 257 I ___ I -__ l Summary of Pathway Selections Pathway I User Selection 1 -- external gamma I active 2 -- inhalation (w/o radon)} active 3 -- plant ingestion l active 4 -- meat ingestion l active 5 -- milk ingestion l active 6 -- aquatic foods l active 7 -- drinking water l active 8 -- soil ingestion l active 9 -- radon l suppressed Find peak pathway doses l active

KQSHAIJ, Version b.-Z Th Limit - 0.5 year 07/27/2004 09:42 Page 8 Summary : 3.71m Landfill Farm File: 02_3.71Fmr.RAD Contaminated Zone Dimensions Initial Soil Concentrations, pCi/g Area: 3965.00 square meters Co-60 4.150E+00 Thickness: 3.71 meters Cs-137 8.500E-01 Cover Depth: 1.22 meters H-3 3.930E+01 Total Dose TDOSE(t), mrem/yr Basic Radiation Dose Limit - 2.500E+01 mrem/yr Total Mixture Sum M(t) - Fraction of Basic Dose Limit Received at Time (t) t (years): 0.000E+00 1.OOOE+00. 3.OOOE+00 l.000E+01 3.OOOE+01 5.000E+01 3.000E+02 1.000E+03 TDOSE(t): 2.348E-0l 5.370E-0l 2.122E+00 2.619E-0l 1.777E-02 1.065E-02 6.606E-05 2.040E-ll M(t): 9.391E-03 2.148E-02 8.488E-02 1.048E-02 7.106E-04 4.262E-04 2.642E-06 8.161E-13 Maximum TDOSEMt): 2.485E+00 mrem/yr at t - 4.529 t 0.009 years Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides Ci) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 4.529E+00 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Nuclide Co-60 1.238E-05 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 5.301E-02 0.0213 1.034E-02 0.0042 1.222E-03 0.0005 0.OOOE+00 0.0000 Cs-137 4.404E-08 0.0000 0.OOOE+00 0.0000 0.00OE+00 0.0000 1.739E-02 0.0070 5.090E-03 0.0020 1.604E-03 0.0006 0.000E+00 0.0000 H-3 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 1.010E-02 0.0041 6.004E-04 0.0002 5.212E-04 0.0002 0.OOOE+00 0.0000 Total 1.242E-05 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 8.050E-02 0.0324 1.603E-02 0.0065 3.347E-03 0.0013 0.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides Ci) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 4.529E+00 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Nuclide Co-60 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 6.458E-02 0.0260 Cs-137 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 2.409E-02 0.0097 H-3 2.106E+00 0.8476 5.152E-05 0.0000 0.000E+00 0.0000 2.023E-01 0.0814 1.994E-02 0.0080 5.657E-02 0.0228 2.396E+00 0.9643 Total 2.106E+00 0.8476 5.152E-05 0.0000 0.OOOE+00 0.0000 2.023E-01 0.0814 1.994E-02 0.0080 5.657E-02 0.0228 2.485E+00 1.0000

Sum of all water independent and dependent pathways.

9-81&#1&V% VV:%4 rage V

'umnmary : 3.71m Landfill Farm File: 02 3.71Fmnr.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 0.OOOE+00 years Water Independent Pathways (Inhalation excludes radon) .

Ground Inhalation Radon Plant Heat Milk Soil Radio-Nuclide mrem/yr fract. mremlyr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

-o-60 2.130E-05 0.0001 0.OOOE+00 0.0000 0.OOOE+00 0.0000 9.384E-02 0.3997 1.831E-02 0.0780 2.163E-03 0.0092 0.OOOE+00 0.0000 Cs-137 4.586E-08 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 1.885E-02 0.0803 5.515E-03 0.0235 1.738E-03 0.0074 0.OOOE+00 0.0000 H-3 0.000E+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 8.495E-02 0.3618 5.021E-03 0.0214 4.368E-03 0.0186 0.000E+00 0.0000 rotal 2.135E-05 0.0001 0.000E+00 0.0000 0.OOOE+00 0.0000 -1.976E-01 0.8418 2.884E-02 0.1229 8.268E-03 0.0352 0.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - O.OOOE+00 years Water Dependent Pathways Water Fish Radon Plant Heat Milk All Pathways*

Radio-Suclide mrem/yr fract. mrem/yr fract. mrem/yr fract. .mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

o-60 O.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 1.143E-01 0.4870 Zs-137 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 .2.610E-02 0.1112 H-3 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 9.433E-02 0.4018 rotal 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.OOOE+00 0.0000 2.348E-01 1.0000

'Sum of all water independent and dependent pathways.

.. a.n U... *q A.uuttL - v.o year UI/Z//UU4 U9:42 Page 10 Summary : 3.71m Landfill Farm File: 02_3.71Fmr.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p3 As mrem/yr and Fraction of Total Dose At t - l.OOOE+00 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Radio-Nuclide mrem/yr fract. mrrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 1.890E-05 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 8.273E-02 0.1540 1.6i4E-02 0.0301 1.907E-03 0.0036 O.OOOE+00 0.0000 Cs-137 4.546E-08 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 l.852E-02 0.0345 5.418E-03 0.0101 1.707E-03 0.0032 O.OOOE+00 0.0000 H-3 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 5.314E-02 0.0990 3.160E-03 0.0059 2.743E-03 0.0051 O.OOOE+00 0.0000 Total 1.894E-05 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 1.544E-01 0.2875 2.472E-02 0.0460 6.357E-03 0.0118 O.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p3 As mrem/yr and Fraction of Total Dose At t - l.OOOE+00 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways-Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 O.OOOE+00 0.0000 O.000E+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 1.008E-01 0.1877 Cs-137 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 2.564E-02 0.0477 H-3 3.136E-01 0.5839 7.347E-06 0.0000 O.OOOE+00 0.0000 2.747E-02 0.0512 2.341E-03 0.0044 8.158E-03 0.0152 4.106E-01 0.7646 Total 3.136E-01 0.5839 7.347E-06 0.0000 O.OOOE+00 0.0000 2.747E-02 0.0512 2.341E-03 0.0044 8.158E-03 0.0152 5.370E-01 1.0000

Sum of all water independent and dependent pathways.

RESRAD, Version 6.21 T&2 Limit - 0.5 year 07/27/2004 09:42 Page 11 Summary : 3.71m Landfill Farm File: 02_3.71F'mr.RAD Total'Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.000E+00 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat

Milk Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 1.487E-05 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 6.428E-02 0.0303 1.254E-02 0.0059 1.482E-03 0.0007 O.OOOE+00 0.0000 Cs-137 4.465E-08 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 1.787E-02 0.0084 5.230E-03 0.0025 1.648E-03 0.0008 O.OOOE+00 0.0000 H-3 0.O00E+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 2.073E-02 0.0098 1.233E-03 0.0006 i.070E-03 0.0005 O.OOOE+00 0.0000 Total l.491E-05 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 1.029E-01 0.0485 l'.900E-02 0.0090 4.199E-03 0.0020 O.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.000E+00 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. *mrem/yr fract. mrem/yr fract. 'mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 .7.832E-02 0.0369 Cs-137 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 2.475E-02 0.0117 H-3 1.764E+00 0.8313 4.300E-05 0.0000 O.OOOE+00 0.0000 1.682E-01 0.0793 1.639E-02 0.0077 4.726E-02 0.0223 2.019E+00 0.9514 Total 1.764E+00 0.8313 4.300E-05 0.0000 O.OOOE+00 0.0000 1.682E-01 0.0793 1.639E-02 0.0077 4.726E-02 0.0223 2.122E+00 1.0000

Sum of all water independent and dependent pathways.

IESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:42 Page 12

u=mary: 3.71m Landfill Farm File: 02 3.71Fmr.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 1.OOOE+01 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 6.426E-06 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 2.657E-02 0.1014 5.183E-03 0.0198 6.123E-04 0.0023 0.000E+00 0.0000 Cs-137 4.194E-08 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 1.577E-02 0.0602 4.616E-03 0.0176 1.454E-03 0.0056 0.000E+00 0.0000 H-3 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 7.685E-04 0.0029 4.569E-05 0.0002 3.966E-05 0.0002 0.000E+00 0.0000 Total 6.468E-06 0.0000 o.oooE+00 0.0000 0.OOOE+00 0.0000 4.311E-02 0.1646 9.844E-03 0.0376 2.106E-03 0.0080 0.000E+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 1.000E+01 years Water Dependent Pathways Water

Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 0.000E+00 0.0000 0.OOOE+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 3.237E-02 0.1236 Cs-137 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 2.184E-02 0.0834 H-3 1.823E-01 0.6961 4.496E-06 0.0000 0.000E+00 0.0000 1.781E-02 0.0680 1.802E-03 0.0069 4.929E-03 0.0188 2.077E-01 0.7930 Total. 1.823E-01 0.6961 4.496E-06 0.0000 0.000E+00 0.0000 1.781E-02 0.0680 1.802E-03 0.0069 4.929E-03 0.0188 2.619E-01 1.0000

Sum of all water independent and dependent pathways.

ESRAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:42 Page 13

ummary: 3.71m Landfill Farm File: 02 3.71Fsmr.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.OOOE+01 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk

Soil tadio- --

auclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

o-60 5.847E-07 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 2.112E-03 0.1189 4.121E-04 0.0232 4.868E-05 0.0027 O.OOOE+00 0.0000

a-137 3.507E-08 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 1.096E-02 0.6169 3.207E-03 0.1805 1.O11E-03 0.0569 O.OOOE+00 0.0000 1-3 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 6.221E-08 0.0000 3.699E-09 0.0000 3.211E-09 0.0000 O.OOOE+00 0.0000 rotal 6.198E-07 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 l.307E-02 0.7358 3.620E-03 0.2037 1.059E-03 0.0596 O.OOOE+00 0.0000

Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (1) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t : 3.000E+01 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-

.uclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

_o-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 2.573E-03 0.1448

_s-137 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 0.000E+00 0.0000 2.518E-02 0.8543 H-3 1.339E-05 0.0008 3.301E-10 0.0000 O.OOOE+00 0.0000 1.307E-06 0.0001 1.323E-07 0.0000 3.619E-07 0.0000 1.526E-05 0.0009 rotal 1.339E-05 0.0008 3.301E-10 0.0000 O.OOOE+00 0.0000 1.307E-06 0.0001 1.323E-07 0.0000 3.619E-07 0.0000 1.777E-02 1.0000

-Sum of all water independent and dependent pathways.

kESRAD, Version 6.21 TS Limit - 0.5 year 07/27/2004 09:42 Page 14 5untnary : 3.71m Landfill Farm File: 02 3.71Fmr.PAD Total Dose Contributions TDOSELi,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 5.OOOE+01 years Water Indepehdent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 5.321E-08 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 2.664E-04 0.0156 3.247E-05 0.0030 3.836E-06 0.0004 O.OOOE+00 0.0000 Cs-137 2.933E-08 0.0000 0.000E+00 0.0000 O.OOOE+00 0.0000 7.547E-03 0.7083 2.209E-03 0.2073 6.958E-04 0.0653 O.OOOE+00 0.0000 H-3 O.OOOE+00 0.0000 O.OOOE+00 .0.0000 O.OOOE+00 0.0000 4.991E-12 0.0000 2.968E-13 0.0000 2.576E-13 0.0000 O.OOOE+00 0.0000 Total 8.253E-08 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 7.713E-03 0.7240 2.241E-03 0.2104 6.997E-04 0.0657 O.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides Ci) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 5.OOOE+01 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 _.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 2.027E-04 0.0190 Cs-137 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 1.045E-02 0.9810 H-3 9.82BE-+0 0.0000 2.424E+-4 0.0000 O.OOOE+00 0.0000 9.599E-+0 0.0000 9.715E-12 0.0000 2.657E-11 0.0000 1.121E-09 0.0000 Total 9.828E-10 0.0000 2.424E-14 0.0000 O.OOOE+00 0.0000 9.599E-11 0.0000 9.715E-12 0.0000 2.657E-ll 0.0000 1.065E-02 1.0000

Sum of all water independent and dependent pathways.

RESRPAD, Version 6.21 Th Limit - 0.5 year 07/27/2004 09:42 Page 1S Summary : 3.71m Landfill Farm File: 02 3.71Fmr.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides li) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.OOOE+02 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant Meat Milk Soil Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 5.173E-21 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 1.790E-18 0.0000 3.493E-19 0.0000 4.127E-20 0.0000 0.0000

_.OOOE+00 Cs-137 3.134E-09 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 4.769E-05 0.7220 1.396E-05 0.2114 4.399E-06 0.0666 O.OOOE+00 0.0000 H-3 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 Total 3.134E-09 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 4.769E-05 0.7220 1.396E-05 0.2114 4.399E-06 0.0666 O.OOOE+00 0.0000 Total Dose Contributions TDOSEli,p,t) for Individual Radionuclides li) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 3.OOOE+02 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-Nuclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Co-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 *2.186E-18 0.0000 Cs-137 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 .6.606E-05 1.0000 H-3. O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.000E+00 0.0000 6.606E-05 1.0000

Sum of all water independent and dependent pathways.

ESRAD, Version 6.21 T4 Limit - 0.5 year 07/27/2004 09-42 Page 16 ummary : 3.71m Landfill Farm File: 02_3.l1Fmr.RAD Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides Ci) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - l.OOOE+03 years Water Independent Pathways (Inhalation excludes radon)

Ground Inhalation Radon Plant

Meat - Milk

Soil Ladio-luclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

o-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000

s-137 5.982E-12 0.2932 O.OOOE+00 0.0000 O.OOOE+00 0.0000 1.041E-11 0.5103 3.049E-12 0.1494 9.603E-13 0.0471 O.OOOE+00 0.0000 1-3 O.OOOE+00 0.0000 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 rotal 5.982E-12 0.2932 0.OOOE+00 0.0000 O.OOOE+00 0.0000 1.041E-11 0.5103 3.049E-12 0.1494 9.603E-13 0.0471 O.OOOE+00 0.0000 Total Dose Contributions TDOSE(i,p,t) for Individual Radionuclides (i) and Pathways (p)

As mrem/yr and Fraction of Total Dose At t - 1.OOOE+03 years Water Dependent Pathways Water Fish Radon Plant Meat Milk All Pathways*

Radio-quclide mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract. mrem/yr fract.

Zo-60 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.'OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Cs-137 0.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 2.040E-11 1.0000 N-3 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 Total O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 O.OOOE+00 0.0000 0.OOOE+00 0.0000 2.040E-11 1.0000

Sum of all water independent and dependent pathways.

RESRAD, Version 6.21 T4 Limit - 0.5 year 07/27/200i 09-i2 Page 17 Summary : 3.71m Landfill Farm File: 02_3.71Fmr.RAD Dose/Source Ratios Summed Over All Pathways Parent and Progeny Principal Radionuclide Contributions Indicated Parent Product Branch DSR(J,t) (mrem/yr)/(pCi/g)

(Mi (j) Fraction* t- 0.OOOE+00 1.000E+00 3.000E+00 1.000E+01 3.000E+01 5.000E+01 3.000E+02 1.000E+03 Co-60 Co-60 1.000E+00 2.755E-02 2.429E-02 1.887E-02 7.799E-03 6.201E-04 4.885E-05 5.266E-19 0.000E+00 Ca-137 Cs-137 1.OOOE+00 3.070E-02 3.017E-02 2.912E-02 2.570E-02 1.786E-02 1.230E-02 7.772E-05 2.400E-11 H-3 H-3 1.000E+00 2.400E-03 1.045E-02 5.137E-02 5.285E-03 3.882E-07 2.851E-11 0.000E+00 0.000E+00

Branch Fraction is the cumulative factor for the j t principal radionuclide daughter: CUMBRF(j) - BRF(1)*BRF(2) ... BRF(j).

The DSR includes contributions from associated (half-life S 0.5 yr) daughters.

Single Radionuclide Soil Guidelines G(i,t) in pCi/g Basic Radiation Dose Limit - 2.500E+01 mrem/yr Nuclide (i) t- 0.000E+00 1.000E+00 3.000E+00 1.OOOE+01 3.000E+01 5.000E+01 3.000E+02 1 .000E+03 Co-60 9.074E+02 1.029E+03 1.325E+03 3.205E+03 4.032E+04 5.117E+05 *1. 131E+15 *1.131E+15 Cs-137 8.142E+02 8.288E+02 8.587E+02 9.729E+02 1.400E+03 2.033E+03 3.217E+05 1.042E+12 H-3 1.042E+04 2.393E+03 4.866E+02 4.730E+03 6.440E+07 8.767E+ll *9.594E+15 9.594E+15 At specific activity limit Summed Dose/Source Ratios DSR(it) in (mrem/yr)/(pCi/g) and Single Radionuclide Soil Guidelines G(i,t) in pCi/g at tmin - time of minimum single radionuclide soil guideline and at tmax - time of maximum total dose - 4.529 _ 0.009 years Nuclide Initial tmin DSR(i,tmin) G i,tmin) DSR(iCtmax) G(i,tmax)

(i) (pCi/g) (years) (pCi/g) (pci/g)

Co-60 4.150E+00 0.000E+00 2.755E-02 9.074E+02 1.556E-02 1.606E+03 Cs-137 8.500E-01 0.000E+00 3.070E-02 8.142E+02 2.834E-02 8.823E+02 H-3 3.930E+01 4.537 +/- 0.009 6.096E-02 4.101E+02 6.097E-02 4.100E+02

KtKiAl, version b.21 Th Limit - 0.5 year 07/27/2004 09:i2 Piage 18 Summary : 3.71m Landfill Farm File: 02_3.71Flmr.RAD Individual Nuclide Dose Summed Over All Pathways Parent Nuclide and Branch Fraction Indicated Nuclide Parent BRF(i) DOSE(j,t), mrem/yr (J) (i) t- O.OOOE+00 l.OOOE+OO 3.OOOE+O0 l.OOOE+0l 3.OOOE+01 5.OOOE+01 3.OOOE+02 l.OOOE+03 Co-60 Co-60 l.OOOE+O0 1.143E-01 1.008E-01 7.832E-02 3.237E-02 2.573E-03 2.027E-04 2.186E-18 0.OOOE+O0 Cs-137 Cs-137 l.OOOE+00 2.610E-02 2.564E-02 2.475E-02 2.184E-02 1.518E-02 1.045E-02 6.606E-05 2.040E-ll H-3 H-3 l.OOOE+00 9;433E-02 4.106E-01 2.019E+00 2.077E-01 1.526E-05 1.121E-09 O.OOOE+00 O.OOOE+00 BRF(i) is the branch-fraction of the parent nuclide.

Individual Nuclide Soil Concentration Parent Nuclide and Branch Fraction Indicated Nuclide Parent BRF(i) S(j,t), pCi/g (j) (i) t- O.OOOE+00 l.OOOE+00 3.OOOE+00 l.OOOE+0l 3.OOOE+01 5.OOOE+01 3.OOOE+02 l.OOOE+03 Co-60 Co-60 l.000E+00 4.150E+00 3.638E+00 2.796E+00 1.113E+00 8.009E-02 5.762E-03 2.973E-17 O.OOOE+00 Cs-137 Cs-137 l.OOOE+00 8.500E-01 8.305E-01 7.929E-01 6.740E-01 4.239E-01 2.665E-01 8.080E-04 7.179E-11 H-3 H-3 l.OOOE+00 3.930E+01 2.441E+01 9.421E+00 3.364E-01 2.464E-05 1.805E-09 O.OOOE+000.OOOE+00 BRFMi) is the branch fraction of the parent nuclide.

RESCALC.EXE execution time - 0.89 seconds

v t e Letter Sequence Request
TAC:L52096, (Approved, Closed)
Initiation Request, Request Acceptance... Administration Questions Answers Results Approval, Approval Other: ML050100035, ML050380027, ML050800436, ML060330095
MONTHYEAR2005-01-19 [Table View]

ML042640208

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