-------
The corresponding incinerated waste volumes are shown in Table 1-31. In all cases, the
incinerator was operated only a few months each year; 6 months in 1986; 7 months in 1987, and
1 month in 1988. Solid wastes were incinerated in 1986, while H-3 contaminated oil was
incinerated during each of the three reported years. The largest volume of oil and the highest
H-3 radioactivity levels were incinerated in 1987.
1.4.2 Commercial Incinerators
1.4.2.1 Scientific Ecology Group Incinerator. The Scientific Ecology Group (SEG) incinerator,
located in Oak Ridge, is designed to process low-level radioactive waste on a commercial basis.
The SEG incinerator is based on a modified European design. The incinerator is used as part
of a larger waste management program which includes waste processing, sorting, compaction,
etc.
Airborne effluent releases and radionuclide distributions in waste and incinerator ashes are given,
see Table 1-32, for the last 3 months of 1989. As can be noted, data parameters are incomplete
for many of the listed radionuclides. In terms of airborne emissions, H-3 and C-14 are by far
the most predominant. Radionuclide emissions for a 3-month period are shown in Table 1-33.
The emissions are associated with the processing of H-3 contaminated oils. Releases, for the last
quarter of 1989, are primarily dominated by C-14 and H-3. All other nuclides are present in
much lesser amounts, typically by four or more orders of magnitude. Some radionuclides, not
listed in Table 1-33, were reported to be at or below limits of detection, and were not reported
by SEG. The decontamination factors (DF) were calculated for those radionuclides with reported
activity for both waste and stack emissions. The DF is expressed as the ratio of radioactivity
reported in waste to that observed in stack emissions. The estimated DFs typically range from
1,000 to 10+u except for H-3, C-14, and 1-129. For these radionuclides, the DF is one
1.4.2.2 Advanced Nuclear Fuels Incinerator. The Advanced Nuclear Fuels (ANF) facility is
located in Richland, WA. The ANF Specialty Fuels Building houses a dual-chamber controlled-
1-59
-------
Table 1-31. Savannah River Site beta-gamma incinerator processed
waste volume and activity: 1986-1988(a)
Part I: 1986 Waste Volumes and H-3 Activity
Month
Processed
Mar.
May
Jun.
Oct.
Nov.
Dec.
Total
Part n: 1987 Waste Volumes
May
Jun.
Jul.
Aug.
Sept.
Nov.
Dec.
Total
Part IH: 1988 Waste Volume
Jan.
Solid Waste
(cubic feet)
3,664
2,608
443
80
48
—
6,843
and H-3 Activity
—
—
—
—
and H-3 Activity
Liquid
Oil - Gal.
—
—
_«
—
435
3,600
4,035
4,276
6,950
2,995
504
400
3,800
3,704
22,629
1,312
Waste
H-3 - Ci
—
__
—
49
409
458
485
789
335
57
45
431
420
2,562
149
(a) Data obtained from DOE/SRS staff, submittal dated 9/28/90. Only H3 has been reported
for the waste cited above. Incinerator shutdown Jan. 1988.
1-60
-------
Table 1-32. SEG incinerator waste, emissions, ash radionuclide distribution for 1989(a;
Radionuclides
H-3
C-14
Cr-51
Mn-54
Fe-55
Fe-59
Co-57
Co-58
Co-60
Ni-63
Zn-65
Sr-89
Sr-90
Nb-95
Zr-95
Tc-99
Ag-llOm
Sn-113
Te-125m
Sb-124
Sb-125
1-129
1-131
Ce-144
Cs-134
Cs-137
Hf-181
Tl-201
Ra-226
Th-232
U-238
Pu-241
Am-241
Cm-242
TRU
Releases or Contents - Ciw DF Ratio
Waste Emissions Ashes Waste/Emission
1.1E-02
2.2E-02
1.5E-O1
1.5E-O1
8.2E-O1
1.8E-02
2.2E-04
3.5E-O1
5.3E-O1
2.4E-01
5.8E-02
1.3E-03
l.OE-02
2.5E-02
9.4E-03
5.2E-04
6.1E-03
3.4E-05
1.5E-06
2.5E-03
6.4E-04
5.1E-06
2.0E-08
2.0E-03
2.3E-O1
7.3E-O1
5.2E-05
2.1E-05
ND
3.3E-07
1.3E-03
2.5E-04
ND
2.0E-07
3.4E-06
1.1E-02
2.2E-02
ND
1.2E-07
ND
ND
ND
ND
1.4E-06
ND
ND
ND
1.1E-14
ND
ND
1.5E-07
1.1E-06
ND
ND
ND
2.6E-07
5.1E-06
2.0E-14 ,
ND
5.3E-07
3.4E-06
ND
ND
ND
ND
4.8E-09
ND
ND
ND
ND
ND
ND
9.9E-03
1.5E-02
ND
ND
2.5E-04
ND
1.1E-O1
ND
3.5E-03
O.OE-OO
ND
ND
2.3E-03
ND
6.6E-03
ND
ND
ND
3.9E-03
ND
ND
1.8E-03
6.1E-03
2.6E-02
ND
ND
1.2E-06
ND
1.3E-03
ND
l.OE-04
ND
ND
1
1
1O6
_
10s
_
_
1011
_
103
103
•
103
1
106
10s
105
10s
-
(a) Extracted from correspondence between SEG and U.S. EPA Region VI, letter not dated.
Represents revised data for the months of Oct., Nov., and Dec., 1989 only,
(b) All values are rounded off and entered as exponential notation; i.e., 1. 1E-02 means
l.lxlO"2. ND means no data.
1-61
-------
Table 1-33. SEG incinerator stack emissions - 4th Quarter 1989**
Radionuclides
October
Stack Releases - Ci(b)
November
December
H-3
C-14
Mn-54
Co-60
Sr-90
Tc-99
Ag-llOm
Sb-125
1-129
1-131
Cs-134
Cs-137
Total-U
(a) Extracted from correspondence
Represents revised data for the
1.7E-11
1.8E-10
O.OE-OO
O.OE-OO
O.OE-OO
1.5E-07
O.OE-OO
6.4E-04
O.OE-OO
1.9E-14
O.OE-OO
O.OE-OO
4.8E-09
5.2E-03
4.9E-03
O.OE-OO
2.8E-07
2.4E-14
8.2E-13
5.8E-07
2.6E-07
O.OE-OO
O.OE-OO
3.6E-07
2.5E-06
2.1E-13
5.5E-02
1.7E-02
1.2E-07
1.1E-06
8.8E-14
6.7E-13
4.2E-07
3.9E-03
5.1E-06
O.OE-OO
1.7E-07
9.3E-07
2.7E-13
between SEG and U.S. EPA Region VI, letter not dated.
months of Oct.,
(b) For the month of October, emissions represent
Nov., and Dec., 1989
releases from both the
only.
incinerator and oil
burner. November and December emissions are for the incinerator only; oil burner was
shutdown. Other radionuclides, if present, were below the detection limits and were,
therefore, not reported by SEG. All values are rounded off and entered as exponential
notation; i.e., 1.7E-11 means 1.7xlO'u.
Packages destined for incineration are sorted and then surveyed to assess the amount of uranium
present. All waste fed to the incinerator is packaged in cardboard boxes to facilitate the
combustion process and minimize ash generation. Ash generated after each burn is collected and
assayed for uranium (UO^ content. If the uranium concentration is found to be elevated, the ash
is subjected to a leaching process to recover the uranium. If uranium is present at low
concentrations, ashes are disposed of at a low-level radioactive waste disposal site.
The ANF incinerator off-gas treatment system is comprised of several components, which
include: a quench column, a venturi scrubber, a packed column, a mist eliminator, a re-heater,
1-62
-------
and a set of HEP A filters. The stack monitoring system consists of a continuous sampling train,
which pulls a sample through a paniculate filter paper. The filter is removed on a weekly basis
and analyzed for alpha radioactivity. Current radionuclide emissions are typically around 10'15
uCi/mL (ANF90).
Waste volumes processed over the past 2 years are summarized in Table 1-34. A total of about
49,100 cubic feet of solid waste and 2.9 million gallons of liquid waste were processed in 11
burn cycles. The duration of a typical burn cycle ranges from about 100 to 1,400 hours,
averaging about 600 hours. The incineration of these wastes resulted in the generation of 538
cubic feet of ash. A total of 4,748 kg of uranium was processed and recovered during this two-
year period. The overall volume reduction factor, using solid waste and spent HEP A filter data,
is estimated to be about 100.
Not included in these totals, ashes excepted, are the waste volumes and amounts of uranium
associated with the incineration of spent HEPA filters. Spent HEPA filters from the off-gas
treatment system are periodically replaced and processed to reduce waste volumes and recover
any trapped uranium. The total volume of spent HEPA filters is about 3,300 cu.ft., also
generated over the 11-burn cycle. A total of 7.3 kg of uranium was recovered from the
incineration of spent filters.
1-4-3 Institutional Incinerator Operations
Typical incinerator effluents were estimated from the survey data described earlier (CRC84).
The nuclear fuel-cycle incinerators were excluded because they are not typical of the large
number of institutional facilities with incinerators, represent only a small number of facilities,
and process unique waste forms. A sample of institutional licensees that incinerate waste was
selected and the activities of the incinerated waste were averaged. For estimating effluents, it
was assumed that 100 percent of the activity incinerated was vaporized and released in the
1-63
-------
Table 1-34. Advanced Nuclear Fuels solid and liquid waste
volumes and uranium mass (a)
Runw
No.
1
2
3
4
5
6
7
8
9
10
11
Total:
Solid Waste(c)
VoUft3) U(kg)
1,418
850
1,530
1,495
3,773
6,580
8,743
2,887
7,210
9,534
5,054
49,074
2.0
21.5
34.1
46.9
170.7
496.6
860.8
288.9
663.4
1,009.0
598.5
4,192.4
Liquid Waste
Vol.(gal) U(kg)
146,035
147,150
145,695
86,112
184,873
459,967
698,927
117,931
335,018
387,799
233,452
2,942,959
0.063
0.779
0.662
1.275
2.633
5.414
10.834
4.256
7.948
13.502
7.667
55.033
Ashes
Vol.(ft3) U(Kg)
4.5
4.0
6.8
10.9
31.4
63.0
114.6
36.9
77.0
120.0 1
68.5
537.6
1.6
25.7
46.9
59.1
159.1
490.9
994.5
384.6
742.9
,145.3
697.6
4,748.2
(a) Extracted from ANF submittal dated 8/14/90. See text for details (ANF90).
(b) Data represent incinerator operation from 8/26/88 to 7/16/90. Each burn cycle is about 600
hrs, on the average.
(c) This tabulation does not include the incineration of spent HEPA filters which are
periodically removed from the incinerator off-gas treatment system. This total volume
amounts to about 3,300 cu.ft. generated over the 11 runs cited above. A total of 7.3 kg of
uranium was recovered from the incineration of such spent filters.
1-64
-------
exhaust. This approach is in fact used by many facilities; it is simply assumed that all of the
radioactivity is exhausted through the stack (EGG80). The amount of radioactivity which is
introduced in the incinerator is limited, knowing its operating characteristics, to ensure that
airborne radioactive releases do not exceed the maximum permissible concentrations allowed by
State or Federal regulations. This approach is usually very conservative in assessing the impact
at downwind locations for most radionuclides, with the exception of tritium, carbon-14, and
radioiodines. Many facilities also have no off-gas scrubbers or filters and do not routinely
monitor airborne emissions.
The predominant nuclides are shown in Table 1-35. The average release rates are given in
curies per year. Tritium and sulfur-35 are the most predominant radionuclides. Carbon-14,
phosphorus-32, chromium-51, and iodine-125 are characterized by lower release rates.
1.4.4 Studsvik Incinerator Operations
Table 1-36 summarizes emissions from the Studsvik Incinerator Facility located in Sweden
(IAE89). This facility processes wastes mainly from nuclear power plants, hospitals, and fuel
fabrication facilities. Some of the waste also comes from other European countries. The IAEA
report notes that the cited yearly releases are all in compliance with Swedish National Institute
of Radiation Protection Standards. This facility was chosen because it processes waste of
varying forms and the radionuclide distribution includes alpha emitters. The incinerator
(multistage excess air system) does not use HEPA filters, but rather relies on a bag filtration
system made of polytetrafluorethylene. In 1983, the radionuclide emissions were associated with
the processing of 355 metric tons of waste (HET90). In 1984, the total waste volume
incinerated was reported to be 435 metric tons (HET90). For either year, releases consist
primarily of H-3 and 1-125, while the other radionuclides are lower by several orders of
magnitude.
1-65
-------
Table 1-35. Effluent release rates for low-level radioactive waste
incinerators - 1984
Major
Radionuclide
Average Release
Rate (Ci/yr)
H-3
C-14
P-32
S-35
Cr-51
1-125
0.1
0.05
0.07
0.1
0.01
0.015
(a) Values are as reported and are not adjusted for the survey response rate. Source: CRCPD
Survey, DOE/ID/12377, 1984 (CRC84).
Table 1-36. Radionuclide emissions from the Swedish Studsvik
Incinerator Facility (a)
Airborne Emissions (Ci/yr)
Radionuclide
H-3
Co-60
Ag-llOm
1-125
1-131
Cs-134
Cs-137
Alpha emitters
Waste quantity
processed (metric tons)
1983
1.4E+0(b)
—
3.0E-4
8.9E-2
5.9E-4
2.5E-5
1.9E-4
9.5E-6
355
1984 (Jan-Aug)
4.3E+1
2.7E-4
—
1.2E-1
3.3E-3
—
7.3E-5
—
435 (full year)
(a) Extracted from IAEA Technical Report Series No. 302, Table XXIX, 1989 (IAE89) and
technical correspondence (HET90).
(b) Exponential notation, 1.4E+O means 1.4 and 1.2E-1 means 0.12.
1-66
-------
1.5 OPERATIONS AND MAINTENANCE PRACTICES AND PROCEDURES
Operations and maintenance practices vary with the particular type of incinerator. Specific
practices pertaining to the various components of incinerator systems are beyond the scope of
this report. However, a few major overall considerations are described below.
A fundamental characteristic of incinerators is that they are designed to function best under
strictly controlled, predictable, steady-state conditions. Uncontrolled variations in the quantity
and physical/chemical characteristics of the waste feed material can have a significant negative
effect both on incinerator performance in terms of the combustion process and on the potential
for air emissions. It is difficult, if not impossible, for incinerators to be capable of responding
rapidly to wide fluctuations in the nature of the feed in such parameters as btu content, ash
quality and quantity, pH of the off-gases, etc. Designing the unit for worst-case conditions it
may encounter for each parameter will not be a satisfactory solution because optimizing for one
condition will likely adversely influence performance in another area. For example, maintaining
the upper limit of temperature for one type of waste will lead to slagging with other types of
waste. Thus, analysis and control of feed material is a crucial aspect of operations. For
radioactive waste, this involves the monitoring of the physical/chemical nature of the feed
(sorting of low-level waste according to combustibility, shredding of dry material, etc.), as well
as its activity levels and radionuclide content.
Process monitoring and control procedures are used to ensure the proper functioning of the
actual incineration process. Chapter 2 describes the focus areas for these procedures. The need
for attention to following proper procedures in monitoring, treatment, and handling of off-gases
and solid residues (ash) obviously is of particular importance for radioactive and mixed waste
incineration. Monitoring technologies are described in Chapter 3.
1-67
-------
1.6 REGULATORY REQUIREMENTS
1.6.1 Nuclear Regulatory Commission Licensing
The Atomic Energy Act (AEA) of 1954, as amended, and the Energy Reorganization Act of
1975 govern the Nuclear Regulatory Commission's (NRC's) authority to regulate incineration
of low-level radioactive waste (LLW). The NRC grants licenses for purposes authorized by the
AEA, subject to favorable findings related to public health and safety, protection of the
environment, and the common defense and security. The NRC implements the AEA with
respect to incineration through Title 10 of the Code of Federal Regulations Parts 20, 30, 40, 50,
51, and 70. The NRC exercises its statutory authority over license holders by imposing a
combination of design criteria, operating parameters, and license conditions at the time of
construction and licensing. It ensures that the license conditions are fulfilled through inspection
and enforcement activities.
By formal agreement with the NRC, a total of 29 States have assumed regulatory responsibility
over byproduct materials, source materials, and limited quantities of special nuclear materials.
These States, in addition to the responsibilities granted by the NRC, have in some cases adopted
additional regulations: For example, Natural and Accelerator-Produced Radioactive Material
(NARM) is covered by some State regulations, although there are presently no universally
applicable regulations for NARM materials.
The NRC's regulations requke an analysis of probable radioactive effluents and their effects on
the population near licensed facilities. The NRC also ensures that all exposures are as low as
is reasonably achievable (ALARA) by imposing design criteria for effluent control systems and
equipment. After a license has been issued, licensees must monitor their emissions and set up
an environmental monitoring program to ensure that the design criteria and license conditions
have been met. For practical purposes, the NRC has adopted the maximum permissible
concentrations developed by the National Council on Radiation Protection and Measurements
(NCRP) to relate effluent concentrations to exposure.
1-68
-------
Li 1981, the NRC issued a policy statement on LLW volume reduction which encourages
licensees to minimize the volume of LLW generated and to use volume reduction techniques,
such as incineration, as a means of reducing the amount shipped for disposal by burial. The
policy statement clearly signaled the NRC's intent to license, on an expeditious basis,
incineration for volume reduction.
The NRC adjusts the review and approval process for applications, dependent on whether the
incinerator is to be used by an institution to reduce its own waste volume, by a commercial
entity to process waste generated by other institutions, or by a nuclear power reactor site.
Applications for institutional incinerators are reviewed by the licensing groups in the Regional
Offices. The criteria for approval are described in Appendix 1. About 70 NRC institutional
material licensees have been authorized to operate LLW incinerators for volume reduction of
their own waste as of December 1989. Approximately 50 were authorized by the Agreement
States as of May 1988.
Applications for commercial incinerators are normally submitted to the appropriate NRC
Regional Office. The information to be provided is the same as outlined for institutional
incinerators, although additional information may be requested as appropriate to assess the
potential impact on public health and safety and the environment.
Licensing of an incinerator at a nuclear power plant can follow one of several paths. The
incinerator vendor can submit a topical safety report to the NRC Office of Nuclear Reactor
Regulation (NRR) for review. The topical report contains the process description, equipment
description, design basis and process parameters, equipment arrangement, sampling/monitoring
equipment description, quality assurance plan description, a discussion of applicable Federal
regulations, and estimated releases for the incinerator. Topical
reports judged by NRR as acceptable may then be referenced in future license applications for
light water reactors. At such time, NRR would perform only a site-specific review of the
1-69
-------
process control program, effluents, monitoring systems, accident analysis, fire protection,
operational procedures, and occupational exposures.
Authorization to operate an incinerator at a nuclear power reactor can be granted as an
amendment to the existing reactor license under 10 CFR 50.59 and 50.92 if the proposed
activities or facility modifications could result in a change in technical specifications or reveal
an unreviewed safety question. The NRC defines an unreviewed safety question as:
1) if the probability of occurrence or the consequences of an accident or equipment
malfunction important to safety issues previously evaluated in the safety analysis
report is increased,
2) if there exists the possibility for an accident or malfunction of a different type
than any previously evaluated in the safety analysis report, or
3) if the margin of safety as defined in the basis for any technical specification is
reduced.
Typically, the NRC would impose additional operational requirements in the plant's technical
specifications. For example, if it were proposed to burn contaminated oils, the plant's
radiological effluent technical specifications would impose limits on the associated airborne
radioactive releases. Recent license amendments have typically limited offsite doses to 0.1
percent of the limits specified in Appendix I to 10 CFR 50, which limit whole-body doses to 5
mrem/yr and 15 mrem/yr to any organ (NRC86, NRC88).
In the case of a nuclear power reactor still under construction, the proposed incineration of
radioactive waste would be addressed in the Final Safety Analysis Report. This approach would
also be used for other types of nuclear facilities licensed under 10 CFR Parts 30, 40, and 70.
In such instances, the licensee would be required to present a report, outlined in Appendix 2,
addressing a number of related safety topics. The licensee would also be
required to submit an environmental report describing the potential impacts associated with the
proposed incinerator.
1-70
-------
The nuclear power plant applicant would also have to demonstrate that the disposal of ash and
waste products would be integrated in the existing radioactive waste management program.
More specifically, it must be shown that the waste thus generated will meet the requirements of
10 CFR 61, titled Management and Disposal of Low-Level Wastes by Shallow Land Burial.
These regulations require waste generators to characterize waste forms and characteristics, as
given in Part 60.56, and segregate such waste according to their classification (A, B, or C) as
specified in Part 60.55. Finally, the shipment of this waste must comply with the requirements
stipulated in 10 CFR 20.311 addressing transfer for disposal and shipping manifests, and the
waste generator must meet any other requirements imposed by the low-level radioactive waste
disposal site. The disposal sites operate under licenses, issued by their respective Agreement
State, which impose site-specific requirements. These requirements are also imposed on waste
generators that ship waste to these facilities.
1-6.2 Resource Conservation and Recovery Act (RCRAVRequirements
All incinerator operations involving the processing of hazardous waste (including mixed waste)
must have a RCRA permit, approved by EPA or an authorized State, to operate within the law.
EPA regulations in 40 CFR 270 indicate the minimum information to be provided by a facility
in order to obtain a permit. Individual States may impose additional or more stringent
requirements. RCRA permit applications are submitted in two sections, Part A and Part B.
Part A provides general information about the facility, including its location, owner, principal
products and processes, hazardous waste handled, and all permits and construction approvals
received or applied for under other programs. Part B must provide more detailed information
about the location and operation of the facility. The application must indicate compliance with
the regulations of 40 CFR 264 aimed at protecting the public health and environment. The
following specific information must be contained in Part B:
a. chemical and physical analyses of the waste to be handled at the facility;
b. a description of security procedures;
1-71
-------
c. a description of procedures, structures, or equipment designed to prevent hazards,
run-off and contamination of water supplies, and undue exposure of personnel to
hazardous waste; and to mitigate the effects of equipment failure or power outages;
d. facility location information including whether the facility is located in a seismically
active area or 100 year floodplain, both of which require additional detailed
evaluation;
e. an outline of the personnel training program;
f. a copy of the facility's insurance policy or other comparable documentation;
g. a topographic map showing, among other things, the legal boundaries of the facility,
surrounding land uses, access control (gates, fences), barriers for drainage or flood
control, and location of operational units within the site;
h. assurances of financial responsibility in the event of damages incurred during or as
a result of operations and for closure;
i. a trial burn plan or comparable information, as outlined in 40 CFR 270.19(C).
The trial burn is required before a permit is granted. Its purpose is to provide evidence that the
incinerator meets the RCRA performance and operating standards (ASM88).
1.6.3 State Regulations
The regulation of air emissions from radioactive and mixed waste incinerators may also be
governed by the State in which the incinerator is located. The 29 NRC agreement States
mentioned in Section 1.5.1, are bound by formal agreements to adopt requirements, applicable
to certain classes of licensees,
that are consistent with and serve in Ueu of NRC regulations. Included in such regulations are
concentration limits for release of effluents, by radionuclide, to unrestricted areas. These
regulations would apply to commercial incinerators or incinerators operated by hospitals, clinics,
or other research and industrial facilities. Federal facilities, such as the DOE incinerators, are
exempted from these regulations. The 29 Agreement States are listed below.
1-72
-------
Alabama
Arizona
Arkansas
California
Colorado
Florida
Georgia
Idaho
Illinois
Iowa
Kansas
Kentucky
Louisiana
Maryland
Mississippi
Nebraska
New Hampshire
New Mexico
New York
Nevada
North Carolina
North Dakota
Oregon
Rhode Island
South Carolina
Texas
Tennessee
Utah
Washington
The State of Illinois, as one example of an NRC Agreement State, has developed and adopted
statutes and regulations (32 Illinois Administrative Code, Chapter II) which cover, among other
activities, the licensing and operation of radioactive waste incinerators. Part 340 of the
regulations, which is a parallel to the NRC's Title 10 Part 20 regulations, provides "Standards
for Protection Against Radiation." Within Part 340, Section 340.3050 states that "No licensee
or registrant shall incinerate radioactive material for the purpose of disposal or preparation for
disposal except as specifically approved by the Department pursuant to Sections 340.1060 and
340.3020." Section 340.1060 addresses concentrations of radioactivity in effluents to unrestricted
areas. Concentration limits by radionuclide are provided in Appendix A, Table II, of Part 340.
Section 340.3020 addresses the method of obtaining approval of proposed disposal procedures.
Copies of these regulations are provided as Appendix 3.
It is important to note that agreement state regulations governing air emissions apply in addition
to EPA NESHAPS regulations. In Tennessee, for example, the commercial SEG incinerator
holds a materials license from the State, and is thus subject to Tennessee's radiation protection
regulations, which are equivalent to the NRC Part 20 regulations. It is also subject to the EPA
NESHAPS regulations for radionuclides. The same situation applies to the DSSI incinerator in
Kingston, Tennessee. However, radioactive air emissions from the DOE Oak Ridge TSCA
incinerator are regulated solely by the EPA NESHAPS requirements. While authority for
implementation of EPA regulations can also be delegated to states, Tennessee does not have
plans at present to seek delegation of authority from EPA for radionuclide NESHAPS
1-73
-------
regulations. Tennessee does have permit authority for nonradioactive air emissions from the
TSCA incinerator.
1-74
-------
Chapter 1 References
ANF90
ASM88
BAR_
BUH89
CAR_
CRC84
DOE89
DOE89a
DOE89b
DOE90
DUK85
DUK90
EGG80
Advanced Nuclear Fuels Corporation, Richland, WA, correspondence to U.S. EPA,
dated August 14, 1990, ANF file reference No. CWM:90:118.
Hazardous Waste Incineration, A Resource Document, American Society of
Mechanical Engineers, ASME Research Committee on Industrial and Municipal
Wastes, January 1988.
Barton R.G. et al. Analysis of the Fate of Toxic Metals in Waste Incinerators,
Energy Environmental Research Corporation and Environmental Protection Agency.'
Thomas Buhl; "Assessment of Radiation Doses and Resulting Health Risks From
the Controlled-Air Incinerator," Los Alamos National Laboratory, July 1989.
Cargo, C.H.; PREPP Criticality Control, EG&G Idaho, Inc.
Conference of Radiation Control Program Directors: CRCPD Survev
DOE/ID/12377, 1984, Frankfort, KY. Y>
Department of Energy; Integrated Data Base for 1989: Spent Fuel and Radioactive
Waste Inventories, Projections, and Characteristics, DOE/RW-0006 Rev 5
November 1989. -.''•'
Department of Energy; Air Quality Permit Application for the Proposed Low-Level
Waste/Mixed Waste Incinerator, Technical Area 50, Building 37 Los Alamos
National Laboratory, Los Alamos, NM, February 1989.
Department of Energy; Environmental Restoration Waste Management Five-Year-
Plan, DOE/S-0070, December 1989.
Department of Energy; Final Supplement Environmental Impact Statement Waste
Isolation Pilot Plant, DOE/EIS-0026-FS, (13 volumes) January 1990.
Duke Power Company filing; "Oconee Nuclear Station Radioactive Waste Volume
Reduction Incinerator," Letter to Harold R. Denton, NRC, from Hal B Tucker
Duke Power, June 10, 1985.
Personal communication between S. R. Phelps of S. Cohen & Associates, Inc., and
David Vaught of Duke Power Company, April 6, 1990.
Interim Report: Low-Level Waste, Institutional Waste Incinerator Program,
EG&G, Idaho National Engineering Laboratory, EGG-WM-5116, April 1980.
1-75
-------
EGG82 Radioactive Waste Incineration at Purdue University, EG&G, Inc. Idaho National
Engineering Laboratory, DOE/LLW-12T, November 1982.
EGG88 Informal Report: Low-Level and Mixed Waste Incinerator Survey Report, EG&G,
Inc. Idaho National Engineering Laboratory, EGG-LLW-8269, October 1988.
EPA87 U.S. Environmental Protection Agency; Mixed Energy Waste Study (MEWS),
Office of Solid Waste and Emergency Response, Washington, DC, March 1987.
EPA89 U.S. Environmental Protection Agency; Draft Environmental Impact Statement for
40 CFR 191: Environmental Standards for Management and Disposal of Spent
Nuclear Fuel, High-Level and Transuranic Radioactive Wastes, September 1989.
EPA90 U.S. Environmental Protection Agency; Hazardous Waste Management System;
Identification and Listing of Hazardous Waste; Toxicity; Characteristics Revisions;
Final Rule, Fed. Reg. Vol. 55, No. 61, 11798, March 29, 1990.
ERD76 Energy Research and Development Administration; Nuclear Cleaning Handbook,
ERDA 76-21, Oak Ridge National Laboratory, October 1979 reprint.
ESC89 Eschenbach, R.C., et al., Process Description and Initial Test Results with the
Plasma Centrifugal Reactor, Forum on Innovative Hazardous Waste Treatment
Technologies: Domestic and International; June 19-22, 1989, Atlanta, GA.
FL089 Flowers, R. H. and Owen, R. G.; "Review of the packaging of LLW and ILW for
disposal," Radioactive Waste Management 2, BNES, London, 1989.
FRA89 Francis, C.J., Starr, T.M., The ANF LLW Incinerator Design and Startup,
Advanced Nuclear Fuels Corporation, Richland, WA, April 1989.
GAL_ Gale, L.G.; PREPP Incinerator Partitioning Studies, EG&G Idaho, Inc. and IT
Corporation.
HET90 Technical correspondence from Mr. Frank Hetzler (Studsvik Nuclear) to Mr. Larry
Coe (SC&A, Inc.), dated February 5, 1990.
HUT90 Telephone communication between Mr. David Hutchins, LANL, and Mr. Jean-
Claude F. Dehmel, , Inc., April 24, 1990.
IAE89 International Atomic Energy Agency; Treatment of Off-Gas from Radioactive Waste
Incinerators, Technical Reports Series No. 302, Vienna, 1989.
INEL88a The Idaho National Engineering Laboratory Site Environmental Report for Calendar
Year 1988, DOE/ID-12082(88), June 1989.
1-76
-------
INEL88b Environmental, Safety and Health, Office of Environmental Audit, Environmental
Survey, Preliminary Report, Idaho National Engineering Laboratory
DOE/EH/OEV-22-P, September 1988. ^'
INEL88b Environmental, Safety and Health, Office of Environmental Audit, Environmental
LAN83
LUK90
NRC83
NRC86
NRC88
PUC90
RET90
RFP82
RIN
TRI89
Landolt, R.R.; Evaluation of a Small, Inexpensive Incinerator for Institutional
Radioactive Waste, Health Physics, Vol. 44, No.6, pp. 671-675, June 1983
Mr. Thomas Lukow, DOE/RFP submittal to U.S. EPA, dated Oct. 29, 1990
Nuclear Regulatory Commission; Incineration of a Typical LWR Combustible Waste
and Analysis of the Resulting Ash, NUREG/CR-3087, Battelle Pacific Northwest
Labs, May 1983.
Nuclear Regulatory Commission; Amendments No. 42 and 53 to Operating Licenses
No. NPF-15, Radioactive Effluents, San Onofre Nuclear Generating Station, Units
2 and 3, August 20, 1986.
Nuclear Regulatory Commission; Amendments No. 115 and 101 to Operating
Licenses No. DPR-58 and DPR-74, Radioactive Effluents, Donald C. Cook Nuclear
Power Plant Units 1 and 2, May 19, 1988.
Mr. John Puckett, DOE/LANL submittal to U.S. EPA, dated Nov. 9, 1990.
Correspondence, Matt Mede, RETECH, Inc. to Jean-Claude F. Dehmel SC&A
Inc., September 21, 1990. '
Rocky Flats Plant Fluidized Bed Incinerator, RFP-3249, Rockwell International
Golden CO, March 8, 1982. '
Ringel, H. and Rachwalsky, U.; Laboratory Experiments on the Volatilization of
Heavy Metals during Waste Incineration, Kernforschungsanlage Julich GmbH
Germany. '
Trichon, M., Feldman, J.; Designing an Incinerator to Handle Mixed Waste Roy
F. Weston, Inc., paper presented at the 1989 International Conference on
Incineration of Hazardous, Radioactive and Mixed Wastes
1-77
-------
UNS82 United Nations Scientific Committee; Ionizing Radiation: Sources and Biological
Effects, 1982 Report to the General Assembly, Annex C, Technologically Modified
Exposures to Natural Radiation, 1982.
WM85 Swearing, F.L.; Waste Management 1985, Incineration of Microspheres.
1-78
-------
2. Technologies for Controlling Incinerator Processes
and Radionuclide Emissions
2.1 PROCESS CONTROL TECHNOLOGY
Process controls maintain the incineration system within safe operating limits. This is
accomplished by a series of control loops that use feedback control, feedforward control, or a
combination, to manipulate the process variables to achieve safe and smooth operation.
For feedback control, information about the controlled variable is fed back to control a process
variable. A typical feedback control loop requires a sensor to measure the variable, a
transmitter to provide a feedback mechanism, and a controller to compare the measured value
with the setpoint value and send a signal to a control element or an actuating device to effect a
direct or indirect change in the controlled variable. Depending on whether the controller is an
operator or an instrument, the control loop can be either manual or automatic. In automatic
systems, the controller can exert control through one or more of the following modes:
On/off: The controlling element is either on or off.
Proportional: The signal to the control element and the resulting response are
proportional to the measured deviation of the controlled variable from the setpoint.
Proportional plus Integral: Used to compensate for the inability of proportional control
to achieve the setpoint value. The integral mode applies a signal to the control element
that is proportional to the integral of the deviation. This causes the controller output to
change as long as a deviation exists.
Derivative Action: The controller anticipates where the process is going by measuring
the rate of change of the deviation from the setpoint and applies a control action
proportional to the rate of change to stop the change.
2-1
-------
For feedforward control, a variable which affects the controlled variable is measured and then
a signal is sent to compensate for the change without waiting for the controlled variable value
to change. Feedforward control improves the ability to respond to process disturbances;
however, since it requires solution of an equation or process model, a combination of feedback
and feedforward control is more desirable.
Selection of the type of control depends on the requirements of the particular system and the
requirements of each control loop. A controlled variable that changes slowly or remains fairly
constant could be controlled manually. Process water flowrate to a packed bed scrubber is an
example of this kind of variable. A controlled variable that changes frequently or rapidly
requires automatic control. Typical examples for incinerators are combustion air flows,
supplemental fuel flows, and incinerator pressure.
The primary control loops for an incinerator are: waste, fuel, air and water flowrates;
temperatures in different parts of the system; pressures in different parts of the system; excess
oxygen concentrations; pH in the process, water system; and levels in process water storage
tanks. Incinerator control functions are summarized in Table 2-1 and described in Appendix 4.
2.2 PROCESS MONITORING TECHNOLOGY
Monitoring systems complement the control systems to ensure safe operation and prevent
emissions of toxic and radioactive materials. Control systems are designed to keep the process
variables within safe operating limits; monitoring systems take over whenever the process
variables approach the operating limits. A properly designed monitoring system keeps the
process variables within safe operating limits with a minimum disturbance to the system. The
three levels of automatic monitoring are: alarms, feed cutoffs, and equipment shutdowns.
2-2
-------
Table 2-1. Incineration System Control Functions
System
Feed System
Variable
Controlled
Solid Feedrate
Sensor
Weigh Belt
Weigh Scale
Control Element
Screw Speed
Scale Weight Setting
Constraints
Maximum Feedrate,
Primary Chamber Temp
lerature, and
Combustion
Controls
Kiln
Liquid Feedrate
Kiln
Temperature
Excess Oxygen
Chamber
Pressure
sec'
Temperature
SCC Excess
Oxygen
Flowmeter
Control Valve
Thermocouple Fuel Control Valve
Water Control Valve
Oxygen Meter FD Fan Damper
Fuel Meter FD Fan Speed
Air Flow Meter
Pressure
Flowmeter
ID Fan Damper
Fuel Control Valve
Oxygen Meter FD Fan Damper
Fuel Meter FD Fan Speed
Air Flow Meter
High Gas Velocity (Secondary Chamber
Residence Time)
Maximum Feedrate, Maximum Liquid
Waste Pressure
High Temperature, Low Temperature
Low Oxygen
High Carbon Monoxide
High Pressure (Low Draft)
High Temperature, Low Temperature,
High Gas Velocity
Low Oxygen
High Carbon Monoxide
-------
Table 2-1. (Continued) - Page 2
System
Variable
Controlled
Sensor
Control Element
Constraints
Controlled Air
Incinerator
Fluidized Bed
Air Pollution
Control
Quench System
Primary
Chamber
Temperature
sec
Temperature
Temperature
Excess Oxygen
Temperature
PH
Level
Total Dissolved
Solids
Thermocouple Air Damper
Thermocouple Air Damper
Thermocouple
Fuel Control Valve
Water Control Valve
Air Damper
Oxygen Meter Air Damper
Thermocouple Control ValveHigh/Low
Temperature
Minimum Process Water
Glass
Electrode
Pressure
Conductivity
Neutralizing Liquid
Control Valve
Control Valve
Slowdown Valve
High Temperature, Low Temperature
High Temperature, Low Temperature
High Temperature, Low Temperature
Minimum Oxygen, High Carbon
Monoxide, Minimum Airflow
High/Low pH
High/Low I^evel
Maximum Dissolved Solids Content
-------
Table 2-1. (Continued) - Page 3
System
Variable
Controlled
Sensor
Control Element
Constraints
Acid Gas
Removal
Packed Scrubber
Acid Gas
Removal
Spray Dryer
Venturi Scrubber
Liquid to Gas
Ratio
Scrubber Water
Flowrate
pH
Liquid to gas
Ratio
Exit
Temperature
Liquid to Gas
Ratio
Water Flowrate
Flowmeter
Flowmeter
Glass
Electrode
Water Control Valve
Water Control Valve
Neutralizing Liquid
Control Valve
Flowmeter Spray Control Valve
Thermocouple Spray Control Valve
See Packed
Scrubber
See Packed
Scrubber
Minimum Water Flowrate
Minimum Flowrate
High/low pH
Minimum Flowrate
Maximum Temperature
-------
Table 2-1. (Continued) - Page 4
System
Variable
Controlled
Sensor
Control Element
Constraints
KJ
Particulate
Removal
Venturi Scrubber
Fabric Filter
pH
Water Flowrate
Pressure Drop
Pressure Drop
Wet Electrostatic DC Voltage
Precipitator
See Packed
Scrubber
See Packed
Scrubber
Pressure
Pressure
Pinch Valve or
Recirculation Valve
Air Dampers or
Compressed air Valves
Sparking Rate Sparking Rate Controller
High Vacuum, High Pressure Drop,
High Temperature
High Pressure Drop,
High/Low Temperature
Corona Discharge
-------
Alarms warn the operator that a monitored variable is approaching an operating limit.
This warning gives the operator time to check the problem and take corrective action.
Any variable that causes a feed cutoff or equipment shutdown should be alarmed before
its value reaches the limit for feed cutoff or equipment shutdown. Occurrence of
feedcutoffs and equipment shutdowns are also alarmed.
Feed cutoffs are activated when a variable goes out of range in a manner that may
produce emissions from the incinerator. Feed cutoffs do not shut down other parts of
the system other than the feed system. When the affected variable returns to the
operating limits, waste material feed is allowed to resume.
Equipment shutdowns are activated when a variable goes out of range in a manner that
may create a dangerous operating condition or cause damage to the equipment. Any
action requiring an equipment shutdown also requires a feed cutoff. Since an equipment
shutdown is the last line of defense, this action causes maximum disturbance of the
process. Shutdown systems should be hard-wired and independent of other controls.
Separate sensors and transmitters should be provided for temperature, pressure, flow,
etc. Signals requiring shutdowns should not be processed through the algorithm of a
programmable controller.
All safety shutdowns and feed cutoffs should require a manual reset by the operator after the
condition has been corrected, and the control console should be provided with a first-out feature
that identifies the primary cause of the alarm, cutoff, or shutdown. All hardware should be
designed to fail in a safe direction. For example, a fuel valve should be designed to fail closed.
Safety shutdown systems require regular checking to ensure operability. A check should include
inspection of the safety circuits and mechanisms to make sure that there has been no tampering,
jumpering, clogging, galling, wearing, corroding, or other irregularity. Instruments should be
calibrated on a regular schedule. Relays and valves should be actuated on a regular basis to
prevent hangups when they are actually needed. Emergency vent valves are particularly prone
to sticking if they are not exercised.
2-7
-------
Incinerator monitoring sub-systems are summarized in Table 2-2 and described in Appendix 5.
2.3 EMISSION CONTROL TECHNOLOGY
Although the bulk of the radionuclides present in the waste will remain in the solid residue from
the combustion chamber, some will be present in the incinerator off-gas. Some will Combine
with the carry-over particulates, others may volatilize from the high combustion temperatures
into off-gas vapor. The off-gas may also contain noxious and/or corrosive gaseous constituents
such as NO3, CO, HC1, HP, and SO2, depending on the chemical composition of the incinerated
waste. The function of the emission control system is to clean the off-gas of particulates and
radioactive, noxious, and corrosive gaseous components. The emission control system,
consisting of components for removal of particulates and gases, must be incorporated in the
incineration system to protect the environment against radiological as well as conventional
chemical hazards.
Emission control systems perform various operations such as cooling, dust removal, acid gas
removal, and hydrocarbon treatment. Each system will have a unique combination of cleaning
equipment to fit the performance requirements of the incinerator and the waste feed. Two basic
types of emission control systems are used. Wet systems utilize cooling or scrubbing devices
to saturate the off-gas stream in intermediate steps, and then heat or dry the gas stream before
final filtration to avoid moisture condensation on the filters. Dry systems do not saturate the gas
stream, although water injection may be used for cooling. Dry emission control systems are
usually used when the PVC content of the waste feed is low, because emission of HC1 is not a
problem. A typical system may include high temperature filtration, cooling, filtration or
separation, adsorption, and high efficiency filtration. Wet emission control systems are used for
treatment of off-gas when removal of HC1, SOX NOX or HF is required. Typical systems may
include off-gas cooling, scrubbing, heating, and high efficiency filtration. The operation of both
wet and dry emission control systems results in secondary hazardous/radioactive wastes,
including filters, adsorption material, liquid scrubber solutions, and blowdowns. Some of these
2-8
-------
Table 2-2. Incinerator Monitoring Subsystems
to
System
Solid Feed
Liquid Feed
Atomizing Media
Limestone
Injection
Primary
Chamber
Variable
Monitored Trip
Shredder
Feedrate
Feedrate
Low Pressure
High Pressure
Low Temperature
Low Pressure
Feedrate or
limestone-to-feed
ratio
High Temperature X
Feed
Cutoff Alarm Records
X X
X
X
X X
X X
X X
X X
X . X X
X X
Incinerator
Type
All
All
All
All
All
All
All
Fluidized
Bed
All
Comments
Shredder must be running for proper feed
preparation
Feedrate must be monitored to satisfy
regulatory requirements
See above
Required for adequate atomization
High pressure may cause overfiiing
Required for adequate atomization for liquid
wastes that require heating
Pressure is needed for adequate atomization
May be required to ensure adequate acid gas
removal
High temperature trip consists of shutting
Low Temperature
X
X
All
equipment
Feed cutoff on low temperature is required
to ensure adequate waste destruction
-------
Table 2-2. (Continued) - Page 2
System
Variable
Monitored
Feed Incinerator
Trip Cutoff Alarm Records Type
Comments
Primary
Chamber
Burner
Loss of Draft X X All
Loss of Draft Feed Cutoff Required to
Minimize Fugitive Emissions from the
Incinerator
Fluidized Feed Cutoff Required to Ensure Adequate
Waste Destruction
Fluidized Feed Cutoff Required to Ensure Adequate
Waste Destruction
Low Oxygen XXX
Concentration or Bed
Analyzer
Malfunction
High Carbon X X X
Monoxide Bed
Concentration or
Analyzer
Malfunction
There are separate monitoring systems for the primary chamber and secondary chamber burner systems
High Fuel Pressure XX All Applied Whenever Burner Is Operating
Low Fuel Pressure X X All See Above
XX All
Low Atomizing
Pressure
Loss of Flame
X
X
All
For Fuel Oil Only
Trip Applies on System Warm-up
-------
Table 2-2. (Continued) - Page 3
System
Burner (cont'd)
Secondary
Chamber
Variable
Monitored Trip
Lack of Air Purge X
Combustion Air X
Pressure
High Temperature X
Low Temperature
Low Oxygen
Concentration or
Analyzer
Malfunction
High Carbon
Monoxide
Concentration or
Analyzer
Feed Incinerator
Cutoff Alarm Records Type
X X All
XX All
X X All
X X All
XXX Rotary
Kiln
Controlled
Air
X X Rotary
Kiln
Controlled
Air
Comments
Applies on Initial Start-up
Trips
and Afterburner
High Temperature Trip Consists of Shutting
Down Secondary Chamber Burners and
Primary Chamber Burners to Protect
Equipment
Feed Cutoff on Low Temperature Required
to Ensure Adequate Waste Destruction
Feed Cutoff Required to Ensure Adequate
Waste Destruction
Feed Cutoff Required to Ensure Adequate
Waste Destruction
Malfunction
High Gas Velocity
X X
All
Ensures Adequate Residence Time for
Waste Destruction
-------
Table 2-2. (Continued) - Page 4
Variable
System Monitored Trip
Air Pollution
Control System
Quench High Exit X
Temperature
Low Exit
Temperature
to
»— >
10 Low Coolant X
Flowrate
Venturi Scrubber Low Flue Gas
Pressure Drop
Low Scrubber
Water Flowrate
High Vacuum
Fabric Filter High Pressure Drop
Wet Electrostatic Low DC Voltage
Feed Incinerator
Cutoff Alarm Records Type
X X All
X X All
X X All
XX All
XX All
X X All
X All
X X All
Comments
Trip Required to Protect Equipment
Feed Cutoff Required to Prevent Clogging
of Baghouses or Shorting of Dry
Electrostatic Precipitators
Trip Required to Protect Equipment.
Feed Cutoff Required to Prevent Excessive
Emissions
Feed Cutoff Required to Prevent Excessive
Emissions
Required to Protect Equipment
Alarmed
Required to Prevent Excessive Emissions
Precipitator
-------
. Table 2-2. (Continued) - Page 5
to
System
Packed Scrubber
HEPA Filter
Carbon bed
General
Subsystems
ID Fan
Instrument air
Electrical
Emission
Monitors
Gases:
Carbon
Monoxide
Variable
Monitored Trip
Low Scrubber
Water Flowrate
High Pressure Drop
High Pressure Drop
Loss of Vacuum X
Low Instrument Air
Pressure
Loss of Power X
Feed Incinerator
Cutoff Alarm Records Type Comments
X X All Feed Cutoff Required to Prevent Excessive
Emissions
x All Filter Requires Changeout
X All Replacement Required
X X All Loss of Vacuum Trips All Burners and
Activates the Emergency Vent
X X All Loss of Instrument Air Causes a
Trip.
X X All Loss of Power Causes a General
General
Trip.
X X X All Regulatory Requirement and Efficiency
Carbon Dioxide
X
All
Calculation
Used for Efficiency Calculation
-------
Table 2-2. (Continued) - Page 6
Variable
System Monitored
Oxygen
Total
Hydrocarbons
Nitrogen Oxides
CulfiiT TlifwiHi=»
Feed
Trip Cutoff Alarm Records
XXX
X
X
X
Incinerator
Type
All
All
All
All
Comments
Regulatory Requirement
I
t—*
*«.
-------
wastes may be processed by incineration. Others may have to be disposed of separately, and
possibly immobilized before disposal.
As an example of emission control, the system used on the controlled air incinerator (CAI) at
Los Alamos National Laboratory consists of an aqueous scrubbing system followed by a dry off-
gas cleaning system. The scrubbing system includes a quench tower, high energy venturi
scrubber, packed-column absorber tower, condenser, and a process system for recycled liquid.
The downstream dry off-gas system includes a superheater, roughing or prefilter, H[PA filters,
and an adsorption tower.
2.3.1 Removal of Particulates
Basically, particulates are removed by filtration, separation, and scrubbing techniques.
Descriptions of major components follow:
2.3.1.1 Filtration
2.3.1.1.1 High Temperature Filters. High Temperature Filters operate in the 1100-2000°F
temperature range. At these temperatures, the filter elements are red hot contact surfaces on
which unburned particles in the flue gas are incinerated. The ash falls off the filter elements
during combustion and collects in the bottom of the filter housing.
Ceramic candle filters, made of silicon carbide, can be used at temperatures up to 2000°F. The
cylindrical filter elements are suspended from support plates inside a refractory lined housing.
When the operational pressure drop is exceeded, the candles are blown back by compressed air
to clean the filters.
Ceramic fiber filters, made of plugs in fine-meshed expanded metal, operate at around 1300°F.
A filter is built up of several plugs assembled vertically. The plugs are lined with a deposit of
asbestos fibers. When the filter becomes clogged, it is cleaned and regenerated with new
2-15
-------
asbestos. Because of the asbestos fibers used, these filters may not be suitable for use in the
United States.
2.3.1.1.2 Baqhouse Filters. Baghouse Filters consist of permeable bags made of teflon felt or
glass fiber which can operate at temperatures up to 500°F. They are sometimes used as
prefilters to reduce the clogging rate of HEPA filters.
Filter fabrics are usually woven with relatively large openings in excess of 50 microns in
diameter. However, smaller particles are captured since filtration employs the combined effects
of impact, diffusion, gravitational attraction, and electrostatic forces generated by interparticle
friction. The dust layer itself also acts as a filter medium. When the filter surface resistance
reaches its capacity due to dust build-up, it must be cleaned. Some cleaning mechanisms
physically shake a bag section, and the particles drop to the bottom by gravity. Compressed air
is also used to inflate the bag and loosen the dust cake, which falls to the bottom.
2.3.1.1.3 High Efficiency Particulate Air Filters. High Efficiency Particulate Air Filters
(HEPA) are constructed of glass fiber mat which produces a particle removal efficiency of at
least 99.97 percent for 0.3 micron particles of dioctylphthalate (DOP) aerosol. These filters are
used for final cleanup of particulates, and will not remove gases. Nuclear grade HEPA filters
must meet requirements specified by the Institute of Environmental Sciences (IES)
"Recommended Tentative Practice for Testing and Certification of HEPA Filters, IES RP-CC-
001-83-T."
HEPA filter assemblies are made up of individual cells that are typically 24 inches high,
24 inches wide, and 11 1/2 inches deep. The filter media consists of nonwoven corrugated glass
fiber (typically boron silicate microfiber) that is folded into pleats, with a corrugated separator
between each pleat if the media is fiat. Adhesive is used to seal the media to a wood or metal
frame. The cell, which may be covered with a metal cloth faceguard for protection, is mounted
in the holding frame with a gasket or fluid seal to prevent the possibility of bypassing unfiltered
gas around the filter. With normal adhesives, HEPA filters can operate up to 250°F. With
2-16
-------
silicone adhesives, temperatures up to 500°F may be tolerated. For high temperatures up to
1000°F, glass packing mechanical seals may be used between the cells and the frame. HEPA
filter media is treated with a water-resistant binder and will tolerate some humidity, however,
excess moisture can plug the filter and result in failure by overpressure. Wood framed filters
are unsuitable for systems with high moisture content since they will expand and warp when wet.
Since HEPA filters are an essential part of an emissions control system, particularly for
radionuclides, they are monitored for pressure drop to ensure their integrity. HEPA filters are
designed for a maximum clean pressure drop of 1 inch HzO. A pressure drop of 2 inches HzO
indicates that the filter is dirty and has reached the end of its service life. The service life of
a HEPA filter depends on the amount of particulates in the off-gas, and can be extended by
removing larger particulates in upstream emission control equipment. Other operating
parameters that indicate possible HEPA filter failure include high temperature and pressure. The
sealant on a HEPA filter subjected to higher- than-design temperature for an extended period of
time will degrade. An operating pressure higher than the HEPA's design pressure may rupture
the filter media. A rupture would be indicated by a decrease in the normal filter pressure drop.
Nuclear grade HEPA filters must be tested while encapsulated for resistance to airflow and
penetration in accordance with Mil-Std-282, DOP Smoke Penetration and Air Resistance of
Filters, at the nominal rated capacity listed in Mil-F-51068 and at 20 percent of that capacity for
penetration. The Mil-Std-282 procedure is known as the "hot" DOP test because thermally
generated dioctylphthalate (DOP) particles are used to challenge the filter. The Q 107
penetrometer test apparatus must be used to ensure that the DOP particles are homogeneous in
size (0.3 micron) in order to form a monodispersed aerosol.
The HEPA filter assembly to be tested is encapsulated in the test box to ensure that any leakage
through the gasket or frame will contribute to the overall penetration. The overall penetration
through the filter can not exceed 0.03 percent (100 percent-0.03 percent = 99.97 percent
efficiency). This efficiency represents the average efficiency of this particular filter. There may
be minute areas of the filter with greater penetration (gasket, frame, or element) but these are
2-17
-------
diluted by the greater volume of clean air passing through the filter. The 20 percent flow test
helps detect major pinhole leaks that may have been missed in the full flow test. At 20 percent
flow a pinhole leak shows up approximately 25 times greater in proportion to total flow,
compared to 100 percent flow. This is because the constriction of air through the pinhole is a
function of the square of the velocity.
Even though all nuclear grade HEPA filters are factory tested, the Department of Energy retests
each filter before shipment to the using facility. When the HEPA filters are installed, they are
tested in-place per ANSI N 510 (standard for testing nuclear air cleaning systems). This in-place
field test, called the "cold" DOP test, is done with a polydisperse DOP aerosol that has a
particle size range from 0.1 to 3 microns. It is used to reveal the presence of any leaks in the
system that may have resulted from shipping the HEPAs or from installation. It is not
considered an efficiency test. The cold DOP test requires the challenge aerosol to be introduced
into the airstream at a distance sufficiently upstream of the HEPA assembly to ensure proper
mixing.
New types of HEPA filters are currently being developed to circumvent some of the inherent
limitation of existing designs and materials. New HEPA filter designs rely on the use of woven
glass-fiber cloth and aluminum separators. These modifications make the filters less susceptible
to structural failure and blow-out, and permit the filters to be used at higher temperatures. Such
filters are being manufactured in England and Germany. German licensing agencies have
authorized their use at a few facilities and are now considering their installation at all new
nuclear facilities (Bergman, Ruedinger-1986, Ruedinger-1988).
In the United States, Lawrence Livermore National Laboratory (LLNL), in cooperation with the
industry, has developed a sintered stainless-steel HEPA filter (Bergman-1990a). The steel
filtration media is made of sintered powder and sintered fibers. Powder grains and fibers are
about 5 urn in overall dimensions. The media is held in place by a steel mesh which sandwiches
the powder grains or fibers in rigid pleats. The stainless-steel HEPA filter is less susceptible
to structural failures and can withstand much higher operating temperatures than its glass-fiber
2-18
-------
counterpart. One of the limitations of stainless-steel filters is that they have characteristically
high pressure drops. For a given flow rate, the stainless-steel HEPA filter would have to be
larger. Tests conducted by LLNL indicate that for a given flow rate and particle penetration,
the stainless-steel HEPA filter would need about 3 times the filtration area of a glass-fiber HEPA
filter. This limitation implies that existing off-gas systems could not be readily retrofitted since
new filter housings would have to be installed to accommodate the much larger steel filters.
Finally, LLNL has indicated that currently, such filters are expensive to make. It has been
estimated that a filter rated at 1,000 CFM with a 1-inch pressure drop would cost about
$200,000, compared to about $200 for a conventional glass-fiber HEPA filter (Bergman-1990b).
In addition to incineration emissions control, HEPA filters are used in virtually all nuclear
facilities for air control. As a result, used HEPA filters are one of the largest single waste
types. Used HEPA filters constitute a high volume, low density waste composed of wood or
metal frames, organic binders and gaskets, glass fiber media, and hazardous and radioactive
contaminants. HEPA filters used in low-level radioactive service can be disposed of by
incineration. Pacific Northwest Laboratory (PNL) conducted tests on incineration of HEPA
filters with simulated transuranic waste. The tests were performed on three incinerators;
electrically heated controlled air, gas heated controlled air, and rotary kiln. The tests confirmed
that all three incinerators could effectively process HEPA filters.
2.3.1.2 Separation
2.3.1.2.1 Cyclones. Cyclones remove particles greater than 10 microns from the gas stream
and are normally used before other control devices such as an electrostatic precipitator or
baghouse. Cyclones are often used downstream of the primary combustion chamber of a rotary
kiln incinerator.
A cyclone removes particles by inertia. The gas entering the cyclone forms a vortex which
reverses direction and forms a second vortex leaving the cyclone. Due to inertia, particulate
2-19
-------
matter moves to the outside wall and drops out the bottom while the gas exits the top of the
cyclone. The temperature range for cyclones is 400-1800°F (refractory lined).
2.3.1.2.2 Electrostatic Precipitators. Electrostatic Precipitators (ESPs) are very efficient at
collecting small-size particulate material suspended in a gas stream. The gas stream passes
through an electric field which induces an electric charge in the particulate matter. The charged
particles collect on a grounded surface, or collector. Particulate matter is periodically removed
from the collecting plates by an internal or external rapping system.
The resistivity of the particulate matter affects ESP design and performance. High resistivity
particles do not give up their electric charge to the collecting electrode and build up on the
collector. Low resistivity particles readily relinquish their charge to the collector, assume the
collector charge, and are repelled back into the gas stream. A particle with the correct
resistivity gives up part of its charge to the collector. The rate at which the charge dissipates
increases as the dust layer builds on the collector. When the weight of the collected particles
exceeds the electrostatic force available to hold the layer, it falls off or is knocked off by the
rapping system.
Since material resistivity varies with temperature, the use of an ESP requires an operating range
where the resistivity is within acceptable limits. The temperature limit for ESPs is usually 300
to 350°F. The off-gas velocity also affects ESP operation.
2.3.1.2.3 Wet Electrostatic Precipitators. Wet Electrostatic Precipitators (WESPs) differ from
ESPs in the method of cleaning the built-up particles from the collector plate. WESPs use water
sprays to saturate or supersaturate the incoming gas stream. The electric field charges the liquid
droplets. The liquid droplets charge, collect, and wash away the particulates from the gas
stream. Resistivity does not restrict WESP operation.
2.3.1.2.4 Ionizing Precipitators. Ionizing Precipitators consist of an ionizer followed by a
packed bed. High voltage ionizer elements charge particulates in the gas stream as they enter
2-20
-------
the unit. The ionizer elements are continuously water washed to prevent particulate build-up.
The charged particles are removed in the packed bed. Particles above 3 microns are removed
by striking the packing; smaller particles are removed by image-force attraction. The packed
bed is continuously washed with water to remove the collected particles.
2.3.1.3 Scrubbing. Off-gas may contain NOX, SOX, HC1, HF, and radionuclides in the form
of aerosols. These gases and particulates can be removed by scrubbing. The offgas is scrubbed
using demineralized water or caustic solution which is circulated by the energy of the off-gas
or an external pump. There are two types of scrubbers. The first, which includes the venturi
scrubber and variable orifice scrubber, removes particulates. These scrubbers will also
neutralize acid gases somewhat, but are not totally effective for gas removal. As a result they
are usually followed by packed-bed scrubbers. The second, which includes the packed-bed
scrubber, impingement tray scrubber, and spray dryer, removes acid gases. These devices will
remove acid gases but are not very efficient at removing particulates from the off-gas stream.
Scrubber effectiveness is related to the pressure drop across the scrubber. Increasing the
pressure drop causes greater turbulence and mixing which results in a more effective scrubbing
action. Scrubbers operate on the principles of interception, gravity, impingement, and
contraction/expansion. Interception occurs when a solid particle collides with a liquid particle.
Gravity causes a particle passing near an obstacle to settle on it. When an obstacle is placed in
a gas stream, the gas will flow around it while the particles will tend to impinge on it.
Contraction in a gas stream produces condensation and turbulence which results in contact
between solid particles and liquid droplets. When the gas stream is expanded, the particle laden
droplets maintain direction while the gas can be diverted and separated.
A wet scrubbing system generates radioactive scrub liquor waste. Scrubbing solution is usually
treated in a subsystem and recycled back to the scrubber. A typical subsystem consists of a heat
exchanger to cool the scrub liquid before entering a circulation tank where it is neutralized with
caustic. From the circulation tank it is pumped to a hydrocyclone to remove particulates and
2-21
-------
then recycled back to the scrubber. The blowdown from the hydrocyclone is filtered to meet
industrial wastewater treatment facility requirements.
2.3.1.3.1 Venturi Scrubbers. Venturi Scrubbers are high energy (high pressure drop), high
efficiency scrubbers usually operating at pressure drops greater than 40 inches H20 for submicron
particle removal. Scrubbing liquid is injected upstream of the venturi throat into the contracted
gas stream at velocities from 200 to 600 ft/sec. The off-gas then passes into an expansion
section where separation occurs. Some scrubbers have adjustable venturi throats to maintain a
desired pressure drop when the flow varies. The venturi only conditions the off-gas, and it must
be followed by other separation equipment to remove the particulates from the gas stream.
2.3.1.3.2 Variable Orifice Scrubbers. Variable Orifice Scrubbers are similar to the venturi
scrubber except a butterfly valve is used in the gas stream to create a venturi effect. The valve
can be adjusted to maintain a fixed pressure drop as the flow changes.
2.3.2 Removal of Gases
Mechanical separation equipment is not effective for removal of volatile or semivolatile elements
and compounds. A chemical or physicochemical liquid or solid absorption reaction is necessary
to remove these constituents from the offgas.
2.3.2.1 Liquid Absorption. Liquid absorption uses water or chemical scrubbing solutions
(NaOH, Na2CO3, CaCOH)^ to react with and remove soluble constituents in the off-gas.
2.3.2.1.1 Packed Bed Scrubbers. Packed Bed Scrubbers consist of vertical towers filled with
packing material. The packing material provides a large surface area for the off-gas to contact
the scrubbing solution. The scrubbing solution (usually water, caustic, or lime slurry) trickles
down from the top of the tower through the packing. The off-gas moves up through the tower
countercurrent to the scrubbing liquid and reacts with it.
2-22
-------
2.3.2.1.2 Impingement Tray Scrubbers. Impingement Tray Scrubbers consist of perforated
baffles and target baffles in a tower. A water level is maintained above the trays. The off-gas
flows through the openings in the perforated plates, against the static water pressure, and around
the target baffles. Scrubbing is caused by the turbulent mixing resulting from the off-gas passing
through the trays.
2.3.2.1.3 Spray Dryers. Spray Dryers consist of cylindrical chambers into which a finely
atomized absorbent such as lime slurry is sprayed. The acid gas in the off-gas stream reacts
with the slurry droplets and forms particulates such as calcium chloride. These particulates are
removed in downstream equipment such as a baghouse filter or electrostatic precipitator.
2.3.2.2 Solid Adsorption. Solid adsorption results from interaction of gas molecules with
activated surfaces. Radioactive gases can be removed by carbon adsorbers, also known as high
efficiency gas adsorbers (HEGA). HEGAs use granular activated coconut shell carbon
impregnated to adsorb radioactive gases. Three types of adsorption occur: kinetic, isotopic
exchange, and complexing or chemisorption. Kinetic adsorption of a gas molecule is the
physical attraction of the molecule to the carbon granule by electrostatic forces. In isotopic
exchange, carbon is impregnated with a stable isotope which exchanges with the radioisotope.
In chemisorption, a radioactive iodine species attaches chemically to a stable impregnant that has
the ability to share electrons. A typical impregnant is triethylenediamine (TEDA) or some other
tertiary amine product. Carbon can be co-impregnated to take advantage of kinetic, isotopic
exchange, and complexing adsorption mechanisms. The type of carbon impregnation and the
residence time required in the HEGA will depend on the radionuclides to be adsorbed.
Carbon adsorbers usually consist of a number of 2-inch thick flat bed cells of charcoal, 24 inches
long and 24 inches wide. Since the adsorption efficiency of charcoal beds is adversely affected
by water vapor, they are normally preceded by condensers and heaters. Because of this, the off-
gas is normally heated above the saturation temperature. However, the temperature is kept close
to the saturation point since adsorber beds operate more efficiently at lower temperatures.
2-23
-------
Carbon adsorber systems are leak tested in place with a test gas, normally freon 11. The
penetration or bypass of the freon measured downstream of the adsorber is compared with the
upstream measurement to obtain the mechanical efficiency. The carbon is tested periodically
(per US NRC Reg. Guide 1.52) for its ability to adsorb. Sampler devices can be included in
the adsorber design. This allows samples to be removed and sent to the lab for processing
without removing the adsorber.
2.4 CAPITAL AND OPERATING AND MAINTENANCE COSTS
It is difficult to estimate incineration costs because of the many factors involved. The type of
waste to be incinerated, the location, size and type of the incinerator, and regulatory
requirements are some of the factors that affect cost. The costs associated with an incineration
system include capital or fixed costs, and operating or annual costs. Cost elements in each of
these categories are listed in Appendix 6.
The capital cost of a hazardous waste rotary kiln incineration system can vary from
approximately $1 million for a 0.5 million Btu/hr unit to over $40 million for a 100 million
Btu/hr unit. The total annual operating costs vary from $2 million for the 0.5 million Btu/hr
unit to $20 million for the 100 million Btu/hr unit.
The capital and operating cost of a radioactive/mixed waste incinerator will be greater than that
of a hazardous waste incinerator. The radioactive/mixed waste system must be designed to
minimize radiation exposure to as low as reasonably achievable (ALARA) levels. This will
necessitate design modifications such as shielding, allowances for easy access, materials of
construction that facilitate decontamination, increased monitoring, and additional emission
control equipment.
2-24
-------
2.5 OPERATIONS AND MAINTENANCE CONCERNS
Appendix 7 contains tables summarizing general operations problems and preventative
maintenance actions. Brief discussions of selected operations and maintenance concerns follow.
2.5.1 Pretreatment
Waste pretreatment is common to most incinerator systems. Accepted operations vary from
hand sorting to automated shredding of bulk materials. Feed size reduction is desirable since
the larger surface area in the reduced size permits more efficient combustion. Typical
maintenance for a pretreatment system includes annual replacement of shredder gears, and
periodic replacement of hoses, sensors, and electronics. Pretreatment considerations include the
following:
Sorting removes difficult to shred or nonincinerable materials, but is a time consuming
process requiring additional installations such as a ventilated sorting area.
Not sorting usually results in corrosive deposits at various steps in the process (fans,
pumps, etc.). PVC, which in the incineration process forms chlorides and highly
corrosive HC1 gas, is a known operational corrosion source in gas phase incineration
operations. In the absence of sorting, noncombustibles such as metals, glass, and organic
liquids may be introduced into the system, and require downstream maintenance and
cleanup of oxidation products and slag.
2.5.2 Feed System
The ram feeder is basically a piston operated component which forces waste into the combustion
chamber. Maintenance and cleanup are required when material becomes lodged behind the ram
face. Installation of a plug conveyor alleviates this problem. Piston seal failure is another
routine operational problem, and seal replacement is generally required after several hundred
hours.
2-25
-------
The screw type feed mechanism experiences gradual wearing of surfaces caused by abrasive
materials. Should the wear become extensive, a chromium based "sweat-on" paste or powder
can be welded to the surfaces. These abrasion-resistant materials significantly extend operational
time. Inspection for feed build-up would be a normal maintenance task during down time
inspection.
2.5.3 Combustion Chamber
2.5.3.1 Rotary Kiln. Typical rotary kiln operation involves introducing the shredded feed into
the rotating kiln operating at 1400-1800 °F for a nonslagging kiln (2800 °F for slagging kiln),
with an accompanying air flow of several hundred thousand actual cubic feet per minute.
Particle size distribution of the feed is the determining factor for feed entry or load point.
Subsequent to initial incineration, the gases pass through a secondary combustion chamber in an
atmosphere of 6-8 percent excess oxygen. For RCRA waste, the secondary combustion chamber
operates between 1600-1800 °F with a residence time greater than 1 second. For TSCA waste
(PCBs), a temperature of 2100-2400 °F and a residence time greater than 2 seconds is required.
The solids from the primary combustion chamber go to the ash collection unit.
Routine maintenance procedures include inspection of the refractory lining to ensure integrity
and inspection of drum internals for possible buckling which can result from uneven heating of
the kiln and degradation of the kiln seals. Seal replacement, bearing lubrication, burner nozzle
replacement, and general cleaning are standard maintenance procedures.
2.5.3.2 Fluidized Bed. Fluidized bed reactor operation involves introducing feed which has
been pretreated so that the typical feed particle diameter is 0.5 inch or less. Air (typically at
a temperature of 1020 °F for radwaste) is fed to a bed containing the feed materials via a hot air
distribution system composed of nozzles connected to a header containing the hot air. As the
velocity of the air increases, the granular bed material (feed) becomes suspended in a churning
gas-solids mixture having physical properties similar to a fluid. Combustion gases are then
processed in the air pollution control system. Typical maintenance procedures include cleaning
2-26
-------
slag which forms in the system, maintaining air distributor nozzles which tend to foul after
extended operation, instrument monitoring such as cleaning of the thermocouple wells which
tend to gather hydrocarbon deposits from the bed, and recalibration of the oxygen and carbon
monoxide monitors.
2.5.3.3 Controlled Air Incinerator. Operating procedures for a typical controlled air incinerator
begin by feeding the pretreated waste to the first chamber (incinerator) either batch wise or quasi-
continuously. The flow of air into the unit is limited to stoichiometric or preferably below
stoichiometric conditions. The oxygen concentration is controlled to keep the local temperature
(at each point of the combusted material) in the appropriate range (1300-1800 °F). The oxygen
concentration is adjusted by partial recycling of off-gas after the water cooling step. The
combustible solid particles and combustible gases leaving the bottom of the incinerator are then
burned in the upper part of the first chamber and finally in the second chamber (afterburner).
The temperature in the afterburner is maintained between 1650 and 2000°F by means of
additional fuel. Total combustion is achieved if the oxygen concentration in the afterburner is
greater than 6 percent by volume. This is typically verified by on-line oxygen analyzers. In the
operating mode, wastes are charged batchwise with the feed depositing on a stationary hearth
in the lower chamber where underfire air is used to support combustion of wastes at near
stoichiometric conditions.
The secondary chamber is operated to provide the necessary residence time for completion of
combustion reactions. Secondary chamber residence time is designed to operate with a minimum
of 1.25 seconds hold-up time.
Typical maintenance procedures for a controlled air system include keeping the pathway from
primary combustor to secondary combustor clean of agglomerated debris, thermocouple
calibration, ensuring scanners are operating, and cleaning up slag that forms from
noncombustibles entering the feed stream.
2-27
-------
2.5.4 Air Pollution Control System
2.5.4.1 Quench Tower. Subsequent to incineration, hot gases and remaining particles are
transferred to a quench tower. The quench tower serves to cool the hot incinerator gases and
prevent high temperature damage to air pollution control equipment. The off-gas exits from the
incinerator or from the afterburner at a temperature of 1650-2370 °F. The off-gas is cooled by
injection of aqueous scrubbing solution directly into the off-gas stream. In the inlet of the
quench tower, some of the scrubbing solution evaporates and the off-gas is rapidly cooled down.
A long contact time is necessary to achieve a vapor-water balance for these temperature
conditions. The temperature of the quench solution at the inlet is kept in the range of 100-115
°F by an external heat exchanger. The acids produced by washing gases such as SO.' HC1, and
HF are neutralized by addition of NaOH or KOH. A part of the solution is removed
continuously or batchwise from the cooling circuit and replaced by scrubbing solution from the
system.
Typical operating problems involve maintaining proper water level in the tower sump,
maintaining proper water flow rates, and controlling tower and water temperatures. Typical
maintenance includes replacing nozzles and cleaning nozzle blockage and/or corrosion of the
nozzle. This is a result of the action of the corrosive incinerator gases reacting with the
moisture in the gases. Pump seal replacement, controls maintenance, and corrosion prevention
(painting, surface passivation) are also typical.
2.5.4.2 Venturi Scrubber. The cooled gases and suspended liquids and solids are usually
transferred to a high energy venturi where the particulates in the stream impinge with the water
droplets carried from the quench tower. A demister system usually operates downstream of the
venturi. Maintenance problems generally focus on corrosion.
2.5.4.3 Baghouse Filter. Baghouse filters made from teflon fleece are used for off-gas
separation and filtration in a temperature range higher than possible for HEPA filters. These are
also used as prefilters to reduce the clogging rate of HEPA filters.
2-28
-------
When acid gases are present, the filter material used is normally teflon felt, formed into
cylindrical bags. Normal operating conditions include a gas velocity of 1 ft/sec at a temperature
of 390 °F and an absolute pressure of 30 psia. In such conditions, with the gas containing about
30 percent water by volume, the residual dust content after filtration is sufficiently low to be
removed by HEPA filters. Standard operating procedures dictate that teflon filters not be
operated above 446 °F for extended periods. Protection against overheating is obtained via a
temperature alarm which automatically opens a bag filter bypass valve. If glass fibers are used,
the operating temperature is in the range of 400-535 °F.
The baghouses are made of stainless steel to resist corrosive environments (HC1, SOz) up to
temperatures of 750 °F. The collected dust accumulates in a hopper. A typical baghouse is
covered by glass wool and aluminum sheeting. This cover acts as an insulator to prevent
condensation on the wall and possible acid corrosion. The bags are sometimes mounted on
metal frames attached to a venturi with a cleaning jet. Maintenance procedures involve
inspection to detect breakage of the bags. Inspection is accomplished by unscrewing and
removing a manhole plate.
2.5.4.4 Electrostatic Precipitators (ESP). In electrostatic precipitation, solid or liquid
particulates suspended in a gas stream are negatively or positively charged and passed through
an electric field, which forces the charged particles to separate from the gas stream and
accumulate on collecting plates for proper operation. Insulation of the high voltage is necessary.
Electricity is supplied as 25-50 KV DC.
The dust layer on the collecting plates is periodically removed by an internal or external rapping
system. An internal drop hammer rapping system provides a greater force to the collecting
plates, but external systems are easier to operate. However, the operating efficiency of the
external system is lower since electrical energy must traverse the entire system to reach the
collecting plates.
2-29
-------
The operating range for electrostatic precipitators is generally dependent on the off-gas velocity,
the presence of conductive material or water droplets, and temperature. The nominal
temperature range is 300-340 °F. Maintenance centers on hydrocarbon deposits which can
produce short circuits, possible corrosion of plates, and high collector plate loading.
2.5.4.5 Wet Electrostatic Precipitator (WESP). WESPs are similar to ESPs except there is a
wet spray in the inlet section to cool the stream, adsorb gases, and collect coarse particles, and
the collection electrode is wetted to flush away collected particles.
Operating procedures include maintaining the proper liquid-to-gas ratio (typically 5 gal/1000 scf)
and a pressure drop from 0.1 to 1.0 inch of water. Typical maintenance includes periodic
washing to prevent particle accumulation on the walls and unblocking nozzles.
2.5.4.6 Packed Tower. As previously discussed, packed towers are used to remove gaseous
components. Operating and maintenance procedures center on water flow, water level, gas flow
rate, tower water distribution, sump level control, unplugging the water flow system, removing
sludge buildup in tower internals, and pump maintenance. Operating efficiency for removal of
NO" or SO. is enhanced by addition of an oxidizing agent such as oxygen or hydrogen peroxide.
2.5.4.7 Condenser. Condenser operation involves cooling the water vapor and separating it
from the stream. The condenser is merely a heat exchanger; it has no moving parts. Thus
standard operations consist of maintaining a proper cooling water flow rate and controlling the
temperature drop across the condenser. Maintenance includes removal of volatile metals which
form, over time, in the tubesheet. Corrosion protection is accomplished via a polymeric gasket
replacement, when required. Tube replacement, if erosion occurs, is another nonroutine
maintenance function. Tube fouling, which reduces the exchanger performance because of a
reduction in the overall heat transfer coefficient, is also a maintenance concern.
2.5.4.8 HEP A Filters. The loading capacity for HEPA filters is rather low compared to other
filters. For this reason, HEPA filters are often protected by prefilters, particularly in high dust
2-30
-------
concentration applications. Use of prefilters is advised if the dust concentrations exceed 0.06
Ib/fts. Operating parameters for HEP A filters are listed in Appendix 7, Table 5.
2.6 INCINERATOR EFFECTIVENESS
Incineration converts combustible waste into ash that is nonflammable, chemically inert, and
more homogeneous than the initial waste. Volume and weight reduction factors to 100 and 20,
respectively, are possible for uncompacted dry active waste, although the overall reduction is
generally lower in actual operation, depending on the method of ash immobilization and the
volumes of secondary waste generated. Loading rate is another measure of effectiveness.
Loading rate is a measure of incinerator efficiency described as feed flux; the higher the loading
the more efficient the combustion. Actual operating values for this parameter are not available
for LLW incinerators.
The efficiency of the off-gas cleaning system for radioactive waste can be obtained by calculating
the system decontamination factor (DF). The system DF is the ratio of the radioactivity in the
feed waste to the radioactivity released subsequent to incineration and off-gas treatment.
DF = Input radioactivity
Output radioactivity
The effectiveness, or removal efficiency, of a given air pollution control component is defined
as:
Removal efficiency = Input activity - output activity x 100 percent
Input activity
= (1 - I/DF) x 100 percent
2-31
-------
Decontamination factors and calculated removal efficiencies for air pollution control components
are given below.
Component
Scrubber
HEPA filter only
HEPA filter + prefilter
Venturi
Electrostatic precipitator
Bag filters
Condenser
Baghouse filter system
Decontamination factor
50-100
100
1000
100
20
15-58
100
100
Removal efficiency
98% - 99%
99%
99.9%
99.9%
99.9%
93.33 - 98.3%
99.9%
.99%
Removal efficiency can also be expressed as a function of particle diameter. Listed below are
actual decontamination factors and removal efficiencies for system components.
Particle diameter, urn
2
10
20
0.3
0.5
1
Component
Decontamination
factor
Venturi
Venturi
Venturi
Bag filter
Bag filter
Bag filter
20
85
99.9
95
96
97
Removal efficiency (%)
95
98.82
98.99
98.95
98.96
98.97
Ash distribution is a further measure of component effectiveness. Typical values obtained from
the Trin Vercellese (Italy) incinerator are:
Component • Ash distribution, percent
Incinerator 93.7
Venturi 1.0
Bag filter 5.2
Beyond bag filter (balance of unit) 0.04
2-32
-------
Lastly, the DF for metals is a measure of effectiveness. Typical decontamination factors for
radioactive metal constituents are:
Metal
Equipment
Co-60
Co-60
Sr-90
Sr-90
Total system
HEPA filter
Scrubber
HEPA filter
15,000
200
3.5
' 445
2.7 INCINERATOR RELIABILITY
Reliability is a measure of the dependability of a system, subsystem, or component. Reliability
coupled with the maintainability of a system, subsystem, or component produces a term known
as availability. In quantitative terms, availability is defined as:
Where:
A
MTBF =
MTTR =
MTBF x 100 percent
MTBF + MTTR
Availability (percent of time that the system, subsystem, or com-
ponent can operate)
Mean time between failure (reliability)
Mean time to repair (a measure of the capability of the unit to
operate)
For incinerator operations, this definition can be simplified to:
A = Time processing feed x 100 percent
Total time
2-33
-------
Reliability studies require rigorous mathematical approaches, their accuracy increases with the
size of the data base, and they are most effective when the units under evaluation operate
continuously. Because there is a general paucity of radioactive and mixed waste incinerator
data, and the limited existing data are from noncontinuous operations, it is not possible to define
availability for radioactive and mixed waste incineration. For comparison
purposes, it should be noted that the typical range for incinerators processing hazardous waste
is 40-80 percent availability.
Materials of construction are a significant reliability concern. Combustors as well as the APC
system can be adversely affected by improper materials selection. Rotary Mlns, for example,
must be designed and constructed so that the refractory lining and the kiln chamber are formed
of materials having similar thermal coefficients of expansion; otherwise, buckling will occur.
Another material failure directly related to reliability is the emission of volatile corrosive gases
from the incinerator system.
Slagging is another reliability factor. This is essentially the buildup of melted noncombustible
materials in the incinerator system that occurs when unsorted materials such as glass, certain
metals, and certain polymeric materials enter the feed stream.
Because radioactive and mixed waste incinerators usually operate in a batch mode, reliability is
hampered by the startup, standby, and shutdown periods of operation. Longer operation periods
could increase reliability. Although not an actual failure mode, increased steady state operation
decreases the starting and stopping stress on components.
HEPA filter failure, primarily from moisture accumulation on the filter material and paniculate
buildup, is another mechanical failure mode. Heating the flue gas to vaporize the moisture will
help this problem and increase reliability. The configuration of the unit is an obvious
contributor to reliability; e.g., parallel HEPA filters have a higher reliability than series HEPA
filters. The interrelationship between operating procedure and equipment causes reliability
predictions based on a limited number of operating systems to be particularly difficult.
2-34
-------
Chapter 2 References
Cooley, Leland R. Incineration in Low-Level Radioactive Waste Management at the University
of Maryland at Baltimore. December 1987.
Martin, Lorenzo M. Notes on Incineration of Radioactive Waste. Consejo de
Seguridad Nuclear. Extract from Energia Nuclear, Spain 28 (148). March-April 1984.
Hultgren, Ake. Practices and Developments in the Management of Low and Intermediate Level
Radioactive Waste in Sweden. Studsvik Energiteknik AB, NW83/502. June 1983.
The Los Alamos Controlled Air Incinerator for Radioactive Waste Volume I: Rationale,
Process, Equipment, Performance, and Recommendations (Abstract only).
Volume II: Engineering Design Reference Manual (Abstract only)
Volume III: Modifications for Processing Hazardous Chemicals and Mixed
Wastes,LA-9427, Vol. 111. DOE/HWP-30. October 1987.
Ziegler, Donald L. and Johnson, Andrew J. Disposal of HEPA Filters by Fluidized Bed
Incineration. 15th DOE Nuclear Air Cleaning Conference, Boston. 1978.
Radioactive Waste Technology. New York, NY. American Society of Mechanical Engineers
1986.
HEPA Filters and Filter Testing. 3rd Edition, Bulletin No. 58ID. Flanders Filters, North
Carolina. 1984.
The Flanders In-Place OOP Test. Bulletin No. 381C. Flanders Filters, North Carolina. 1984.
Flanders Nuclear Grade HEPA Filters. Bulletin No. 812E. Type B Filter. Flanders Filters,
North Carolina. 1988.
Marshall, M. and Stevens, D.C. A Comparative Study of In-situ Filter Test Methods. In
Proceedings of the 16th DOE Nuclear Air Cleaning Conference held in San Diego, California
October 1980.
Treatment of Off-Gas from Radioactive Waste Incinerators. Technical Report Series No. 302.
International Atomic Energy Agency, Vienna. 1989.
Iroju, M. and Bucci, J. Savannah River Plant LLW Incinerator: Operational Results and
Technical Development. Presented at the Incineration of Low-level Radioactive and Mixed
Waste Meeting, St. Charles, Illinois. April 1987.
2-35
-------
Bergman, W. Review of Some Health and Safety Aspects of the Incinerator Planned for the
LLNL Decontamination and Waste Treatment Facility (DWTF). Lawrence Livermore National
Laboratory. December 1988.
Bergman-1990a, High Efficiency Steel Filters for Nuclear Air Cleaning, 21st DOE/NRC Nuclear
Air Cleaning Conference, Werner Bergman, 1990.
Bergman-1990b, High Efficiency Paniculate Air (HEPA) Filters in the Nuclear Industry;
Comments on Previous Reviews, Lawrence Livermore National Laboratory, Werner Bergman,
et al., July 19, 1990.
Ruedinger-1988, The Realization of Commercial High Strength HEPA Filters, 20th DOE/NRC
Nuclear Air Cleaning Conference, V. Ruedinger, et al., August 1988.
Ruedinger-1986, Development of Glass-Fiber HEPA Filters of High Structural Strength on the
Basis of the Establishment of Failure Mechanisms, 19th DOE/NRC Nuclear Air Cleaning
Conference, V. Ruedinger, et al., August 1986.
High Efficiency Gas Adsorbers (HEGA). Charcoal Service Corporation. Bulletin No. 283A,
Bath, North Carolina.
Los Alamos Incinerator Documents:
Treatment Development Facility, Controlled-Air Incinerator, Runlog. Feed Summary for the
Los Alamos Controlled-Air Incinerator System (1978-1987).
Radioactive Operations in the Los Alamos Controlled-Air Incinerator. Appendix D: Radiation
Protection and Plant Instrumentation (From FSAR). Appendix E: Airborne Radioactive
Emissions History (1981-1987).
Air Quality Permit Application for the Proposed Low Level Waste/Mixed Waste Incinerator,
Technical Area 50, Building 37, February 1988.
A review of the report, "High Efficiency Paniculate Arresters in the Nuclear Industry," by
Joseph Goldfield, Consulting Engineer, Reviewer: Ronald C. Scripsick, Industrial Hygiene
Group, LANL, August 17, 1989.
Rocky Flats Incinerator Correspondence and Documents:
Draft Waste Analysis Plan, September 18, 1987.
Regulation Permit Activities for the Rocky Flats Mixed Waste Fluid Bed Incinerator Unit, April
22, 1987.
2-36
-------
3. Technologies for Monitoring Incineration and
Radionuclide Airborne Emissions
The incineration of low-level radioactive and mixed wastes results in the release of airborne
emissions. Emissions include chemical compounds, gases, vapors, and aerosols in the form of
fumes and particulates. Depending on the radiological, chemical, and physical properties of the
incinerated waste, emissions may consist of a wide spectrum of radioactive aerosols (AMB86,
C0081, INC89, OPP87). Airborne release rates also depend on the combustion process and the
type of off-gas treatment system installed on the incinerator (INC89). The types of treatment
technologies most frequently used include high efficiency particulate air (HEPA) filters and
carbon adsorbers (IAE89). Such treatment technologies have proven effective in most routine
applications but are ineffective for some radionuclides, primarily tritium, carbon-14, and iodines.
Tritium is exhausted as water vapors, carbon-14 as carbon dioxide, and iodines are combined
with other organic constituents present in off-gases. For these radionuclides there are no reliable
engineered systems with which to control such emissions. Since airborne radioactive emissions
are regulated by State and Federal agencies, it is necessary to (1) demonstrate that the
incinerator is not releasing radioactive materials in excess of maximum permissible
concentrations (MPCs) and (2) conduct periodic radiological assessments for characterization of
offsite exposures and for historical and record keeping requirements (AMB86). These
requirements are met by sampling and monitoring stack releases for radioactivity and release
rates.
3.1 RADIONUCLIDE AIRBORNE EMISSIONS MONITORING TECHNOLOGY
Conceptually, the methods for sampling and monitoring radioactive emissions are similar to
those used for sampling nonradioactive emissions. In fact, some methods identified by the
Environmental Protection Agency to demonstrate compliance with the Clean Air Act (EPA89)
are useable with little or no modification. In simple terms, a sample is withdrawn from the
exhaust stack at a specified rate, conditioned to minimize sample losses, and collected in a
manner which accounts for the physical properties and chemical forms of the radionuclide(s) of
3-1
-------
interest. The sampling system, known as a sampling train, includes the sampling probe, sample
collection or monitoring device, a flowrate meter, a sampling pump, and the associated
electronic controls and display monitors. The sampling system can be fully automated, manually
controlled, or a combination of the two methods. Depending on monitoring requirements, stack
releases can be monitored in real time or by indirect methods. For example, stack samples can
be collected automatically, removed manually from the sampling train, and analyzed at a later
time. Sample analyses can be performed in real time by continuously operating radiation
monitoring systems, or at a later time in a laboratory. Real-time stack monitoring obviously
offers the advantage of being able to detect current trends in stack emissions and to terminate
immediately the incineration burn if a pre-specified concentration limit is exceeded. This
approach also has the advantage of detecting rapidly changing conditions and monitoring system
parameters that, if unchecked, could result in an unsafe operating status. In this mode, the stack
radiation monitoring train doubles as a process control system.
3.1.1 Stack Off-Gas Sampling Systems
The stack off-gas sampling system generally consists of several components operating as a unit.
The main purpose of the sampling system is to collect a representative sample of the effluent
stream. The EPA regulations, as well as proper practice, require that the sample be withdrawn
isokinetically; i.e., the velocity of the sample gas at the inlet of the sampling nozzle must be
equal to the velocity of the off-gas effluent in the stack (EPA89, ACG78). Failure to meet this
requirement would result in an inaccurate representation of particle size distribution (ACG78).
This requirement is not as critical for gaseous emissions, but since gases and particulates are
always released simultaneously, it is normal practice to sample isokinetically for both using a
single probe. Depending on the type of incinerator, the system can be operated in an automatic
or a manual mode. Depending on its complexity, the system requires such utilities as electrical
power to run pumps, valves, heat tracing elements for sample conditioning, and to power system
interlocks and local and remote alarms; compressed air or bottled nitrogen tanks to purge
sampling lines; and water to cool system components (NRC86, SAI85, SOR89, BUN89, AER84,
TER88, and VIC_J.
3-2
-------
Three basic types of sampling trains and components are commonly used. A typical radionuclide
sampling and analysis system is shown in Figure 3-1. This system can neither detect nor
measure some radionuclides; e.g., tritium and carbon-14. Impingers or silica gel towers, as
indirect methods, are used for this purpose since they have been shown to effectively retain
water vapors and can be made to trap carbon dioxide. Some radiation monitoring systems
respond to other forms of radiation for which they were not originally designed or calibrated.
In such events, the detector(s) will detect radiation being emitted by the sample, but it will not
be possible to reliably measure or quantify the amount of radioactivity actually present. This
type of response, if not properly accounted for during calibration, may result in over or under
estimating actual off-gas releases.
The system shown in Figure 3-1 incorporates a sequence of three radiation detectors. The first
detects and measures radioactive emissions in paniculate forms using paper or glass fiber filters.
The second detects and measures radioiodines using activated carbon cartridges to capture both
elemental and organic iodines. Such cartridges are impregnated with potassium iodide (KI) or
triethylenediamine (TEDA) in order to increase the collection efficiency of organic compounds
(ACG78). The third detector measures radioactive gases by presenting a gas volume to the
detector.
A conceptual diagram showing an example stack monitoring system is shown in Figure 3-2.
This system uses a CaF(Eu) detector capable of operating at the stack gas temperature. By
measuring particulates collected at the stack gas temperature, the adverse effects of particulate
plate-out and deposition/resuspension are eliminated (SEGJ, In all stack monitoring systems,
some effluent components, particularly iodines, will plate-out onto sampling line surfaces. After
plating-out or depositing onto surfaces, iodines will later resuspend, remain suspended for a
time, deposit again, and the process repeats. Because of this phenomena, iodine concentrations
measured by the detector do not represent the true concentractions present in the stack.
Variables that control plate-out are sampling line construction material, diameter, length, and
bends; air flow rate; humidity; change in temperature; and temperature. Temperature is the
major controlling variable. The solution to plate-out is to place the detector on the stack or heat-
3-3
-------
Isokinetic
Nozzles
LEGEND
tSj Ball Valve, Manual
E " 3-Way Electric Valve
PT Pressure Transmitter
RE Radiation Detector
H Motorized Valve
RIC Ratemeter
FE Mass Flowmeter
FIC Flow Indicating Controller
FT Flow Transmitter
Motorized Valve
Fl Flow Indicator
Figure 3-1. Typical Radioactive Airborne Emission Sampling System
3-4
-------
-Stack Exhaust
Stack
• Iiokln.tic Notll*
Sample Flow
Stack Monitor
Inl«t
Sample
Return
Puro,e Ate Absolute
Pure.. Lint 1§) ©
&-
Moving
rarticulnt
Fixed
F^rtlc'il*
Incline
jr°
Samp|.
Peturn
Tritium Sampler ^Jta
KJ ucy
i T
*
O
Temperature
Figure 3-2. Conceptual Diagram Showing the Stack Monitor Location and Sampling Layout
3-5
-------
trace the entire length of the sampling line from the stack to the detector.
Figure 3-3 depicts an EPA-approved sampling system and method for the collection of
particulates. The method relies primarily on the collection of particulates on a filter followed
by a series of impingers. The sample is conditioned to minimize internal losses and maximize
absorption. The particulate filter holder is heated to prevent condensation and the impingers are
cooled in ice baths to enhance absorption. Obviously, the number of impingers can be
increased, and the composition and sequence of each scrubbing solution can be changed to trap
specific chemical species. Other than sampling parameters such as flow rate, temperature, and
differential pressure, this method does not provide any real-time indication of offgas release rates
or concentrations. The filter and impinger solutions are analyzed in a laboratory.
The third method, shown in Figure 3-4, is used to assess the presence and concentrations of
volatile organic compounds. This method relies on the collection of organic vapors on tenax,
charcoal, and silica traps. However, it does not provide any real-time indication of releases as
they occur. The traps, including the silica gel, are analyzed by laboratory methods.
The physical configurations of the systems discussed above are designed to facilitate the
operation of the system, sample changes, and maintenance and servicing. They are typically
configured to reflect specific facility design and operational requirements. The purpose and
operational features of each of the major components are discussed below.
3.1.1.1 Sampling Point Location. The sampling probe is installed in the stack at a location
downstream from any major air disturbances such as elbows, transition pieces, and branch
entries. The normal requirement is to locate the sampling point at a distance equivalent to at
least eight stack diameters downstream from the nearest air disturbance and more than two stack
diameters upstream from any other similar air disturbances (ACG84).
This location can also be determined empirically by taking measurements until the observed flow
rates are within 10 percent of one another at two separate locations (ACG84). The flow rate
3-6
-------
Ttmperaturs
Indicator
Thermocouple (behind)-' ff
"
JOOmL (ea) 0.1N NaOH Emptu Silica Gel
Mag nehelic Gauges
Figure 3-3. Typical EPA Particulate Airborne Emission Sampling Sytem
3-7
-------
Glass or Teflon Pro te
•*-CNrco«l Filter
(for leak checks)
Bulb
(for purging)
Glass Wool
Participate Filter
Dry Gas
Meter
Vacuum
Pump
Figure 3-4. Typical EPA Volatile Organic Sampling System
3-8
-------
across the diameter of the stack is measured by taking two sets of measurements at 90 degrees
from one another. The number of measurements across each traverse is dictated by the shape
and size of the stack pipe. For round ducts with diameters larger than 6 inches, at least 10
traverse points should be used for proper assessment of the cross-sectional flow-rate profile. For
square and rectangular stacks, the procedure involves dividing the cross section into equal square
or rectangular areas and taking measurements in the center of each. Enough measurement points
should be identified such that the distance between any two points is not more than six inches.
The total number of readings should be at least 16 (ACG84).
3.1.1.2 Sampling Probe Assembly. The sampling probe assembly typically consists of one or
more nozzles facing the out-going offgas flow (see Figure 3-5). The shape and size of the
sampling probe and nozzle are designed to minimize air-flow disturbances and collect particulate
and gas or vapor samples with the least loss. The probe is typically shaped such that little or
no internal deposition occurs for particulates (ACG78, ACG84, ANS69, KUR__). The sampling
probe should make a smooth turn with a radius wide enough to minimize sample deposition.
If reactive gases and vapors are sampled, some internal plating may occur. In this case, the
probe material should be selected so as to minimize this undesirable effect (ACG78, AMB86).
Depending on the design, the sampling probe assembly may also incorporate flow rate or
velocity sensors. Stack flow rate or exhaust velocity is measured by a pilot tube or electronic
anemometers (ACG78, KUR_J. These measurements are used to control electronically the
sampling flow rate by regulating the sampling pump or flow control valve. This information
is also used to correct sampling flow rates to conditions of normal temperature and pressure (25
degrees C and 760 mm of Hg) (ACG78).
3.1.1.3 Sampling Flow Rate. The sampling flow rate is dictated by several factors, including
offgas exhaust flow rate, type of sample collection device, instrument response, and desired
minimum detectable airborne concentrations (NRC86, BUN89, BAT83). Generally, these
factors are considered as operating specifications and are incorporated in the general design of
the sampling system. For example, a system with a higher flow rate is not necessarily better
3-9
-------
MOT SHIELDED S.S.
HIGH TEMPERATURE CABLE
TYPICAL SAMPLING NOZZLE.
• VARIOUS SIZES AVAILABLE
(1/4. 5/18, 3/1, 1/T)
SENSOR
• ELECTRICAL
CABLES
SAMPLE FLOW TO
* SAMPLING SYSTEM.
FILTER IMPACTOR, ETC.
FLOW
FLOW
Figure 3-5. Typical Isokinetic Sampling Probe
3-10
-------
since it may sample under anisoMnetic conditions, result in lower sample collection efficiency,
cause increased filter loading, or deplete trap or impinger solvent.
.3.1.1.4 Sample Collection. The sample is extracted from the offgas exhaust stream and
directed to a collection device. Depending on the physical and chemical properties of the
sample, different types of collection devices may be used. For particulates, the sample is
collected on glass-fiber filters, impingers, cascade impactors, or bubblers. If bubblers are used,
scrubber solutions are selected to account for the chemical properties of the sample and to
enhance absorption and retention (AMB86, BUN89, OPP87). For gases or vapors, the samples
are usually collected using impingers with appropriate solutions. Some gases and vapors may
also be collected on activated carbon cartridges or silica gels.
In some instances, the sample may be directed to a direct reading detector which provides an
instantaneous reading. These instruments may consist of beta or alpha scintillation detectors or
gamma or X-ray spectroscopy systems (ACG78, VIC_. SOR89, SAI85). The detection
capability of such systems depends on several factors, including the type of radiation detector,
sample flow rate, ambient background radiation levels, presence of two or more radionuclides,
and the selected radionuclides of interest on which the calibration is based. See Section 3.1.4
for more details on this subject. The sample can be collected on stationary particulate glass fiber
filters, moving filter tapes, activated charcoal cartridges, or presented as a gas volume to a
radiation detector.
Most sampling systems, because of the harsh operating conditions, are equipped with purge lines
to flush out residual gases or particulates between sampling batches. The sampling lines are
flushed with compressed air or bottled nitrogen. The length of the sampling line should be as
short as possible and have a minimum number of bends or turns to minimize internal deposition
(ACG78, ANS69).
Depending on sampling conditions, samples may have to be collected in a controlled
environment. For example, the sample offgas stream may have to be maintained at an elevated
3-11
-------
temperature to minimize water condensation and losses via internal plating (AMB86, OPP87,
ANS69). Experience has shown that when a sampling train is properly designed, little or no
radioactivity should pass through the filters or impingers. The following summarizes some test
results conducted on the TSCA incinerator system located at the Oak Ridge National Laboratory
(BUN89).
Proportion Collected (percent)
Form of Activity
Uranium
Alpha
Beta
Technetium
Filter
& Probe
100
99.25
99.30
99.70
Condensate
ND*
0.68
0.40
0.28
Impingers
ND
0.07
0.30
0.02
*ND means not detectable.
These data indicate that over 99 percent of the activity is retained on the filter and probe. These
values do not represent radiation monitoring system detection efficiencies, but rather the amount
of radioactivity retained in or on various components. Typically, less than 1 percent passes
through the filter and is collected either as condensate or in the impingers. Temperature
conditions are maintained with electric strip heaters and thermally insulated boxes which house
the sample collection devices. The presence of excess water vapor may cause particulate filters
to saturate and rupture as the differential pressure across the filter increases. If samples are sent
to impingers, the sequence of the scrubbers may also be important in isolating particulates
(BUN89). For example, the first two impingers could contain nitric acid to collect uranium,
while the next series of impingers could contain sodium hydroxide to collect elemental iodines
or other particulates. The next impinger could contain impregnated charcoal to trap methyl
3-12
-------
iodines or other organic iodine compounds and any remaining elemental iodines. The final
impinger could contain silica gel to collect any remaining moisture. In this example, samples
from each impinger would be analyzed for the presence and concentration of each radioactive
species. Obviously, this method does not provide the capability to measure airborne
radionuclide emissions in real time.
Typically, the analysis would be performed on a batch basis following each burn or conducted
periodically; e.g., daily. Sample collection and analytical frequency would have to reflect the
chemical stability of the samples, radioactive half-lives, regulatory requirements, and established
minimum detectable concentration limits.
3.1.1.5 Sampling Pump. The sampling pump provides the driving force to draw the sample
from the stack and through the various collection devices (ACG78). The type of pump most
often used is a constant flow-rate pump which adjusts automatically to changing sampling
conditions; e.g., increases in filter loading. Since isokinetic sampling conditions must be
maintained, the sampling flow rate can be adjusted by controlling the pump flow rate or via a
flow-control valve. The sample flow rate is also adjusted to account for differential pressures
and moisture content of the sample stream. Such corrections can be made electronically or
manually depending on the sophistication of the sampling system. These functions are typically
monitored and controlled by flow rate, mass, or velocity sensors and controllers (ACG78,
KUR__ ). Finally, the pump's exhaust is returned to the stack, at a point downstream from the
sampling point. The pump's flow rate must be regularly verified and calibrated to ensure that
operating characteristics have not degraded beyond the useful performance range (ACG78).
Experience has shown that sampling systems are also prone to frequent failure and require
extensive maintenance (IRU ). The accumulation and condensation of corrosive vapors or
gases in sampling lines and components cause rust and corrosion damage. Typically, particulate
residues accumulate in sampling lines, valves, and components and eventually such systems
become plugged and no longer meet original performance specifications. Accordingly, sampling
system designs should consider the use of inert materials, system components that can be quickly
3-13
-------
changed and easily cleaned, and selection of parts and equipment known for their durability and
reliability.
3.1.2 Real-Time Radiation Monitoring Systems
Very complex systems are required to monitor in real time the very low radionuclide
concentrations that may be discharged from incinerator stacks. Real time monitoring requires
alpha, beta, and gamma analysis of particulates and gaseous species with widely different
collection characteristics. While several different real time, or near real time, systems have been
installed, for example, beta/gamma systems on nuclear power plant exhaust stacks, none have
been installed on incinerator stacks.
Sampling systems that incorporate a real-time radiation monitoring system rely on passing or
collecting the sample next to a radiation detector (ACG78). For alpha emitters, the monitoring
system may be equipped with silver activated zinc sulfide. For beta emitters, the detector may
use a plastic scintillator. For gamma or x-ray emitters, the detection system may rely on a
sodium iodide or germanium detector (NCR78).
Some monitoring systems use hybrid designs combining different detection methods. For
example, one method combines alpha and beta scintillation media as one unit. This method
relies on the different attenuation and response properties of beta plastic and alpha ZnS(Ag)
scintillators. Another approach involves placing two separate detectors to measure the
radioactivity collected by a single-filter. For example, one detector could measure total beta
activity while the other could detect total gamma activity or operate as a single channel analyzer
targeting one radionuclide; e.g., iodine-125, iodinelSl, or cesium-137.
More sophisticated systems may rely on analytical spectroscopy by using a surface barrier
detector (Si) for alpha emissions and NaI(Tl) scintillation or solid state (HPGe, Si(Li)) detectors
for gamma or x-ray emissions. The pulses that such detectors generate are amplified, shaped,
collected, and displayed or stored as they are accumulated. In spectroscopy systems, the pulses
3-14
-------
are sorted as a function of energy since such systems generate pulses proportional to the
radiation particle that is detected. The information characterizing the size of the pulses is stored
in energy bins or channels. These data are displayed to generate a spectrum that characterizes
the radionuclides detected on the filter. Since each nuclide has a unique spectrum, this
information can be used to identify each radionuclide and quantify its concentration.
The information thus collected is typically displayed in real-time as a count rate, in counts per
minute (cpm) or second (cps), or directly converted to the proper radiological units, as a
concentration (uCi/mL) or release rate (uCi/sec). These results can be expressed by individual
radionuclide or in terms of total activity for a given distribution of nuclides. Typically, the most
sophisticated systems rely on algorithms which reduce the spectra to the respective radionuclides
and calculate release rates and concentrations given the stack exhaust flow rates (SOR89, SAI85,
VIC ). Given that waste is incinerated in intermittent batches, airborne radionuclide emissions
represent average concentrations or release rates, and a more appropriate radiological measure
may be the rate of change in concentrations or release rates. This information is typically
expressed as cpm per second or uCi/s per second (cpm = counts per minute and uCi/s = micro
curies per second). These sophisticated systems also have the capability to display this
information as a function of time showing trends and variations in concentrations or release
rates. Selection of the proper radiological unit for expressing airborne radionuclide emissions
depends on the type of monitoring system installed, its degree of sophistication, reporting
requirements, State or Federal regulations, and license conditions imposed on the facility.
Finally, real-time radiation monitoring systems must be periodically calibrated against known
radioactive standards (ACG78, NCR78). The operating characteristics and response of such
instrumentation must be known over a wide range of radiation emission energies and anticipated
radioactive concentrations. As discussed in Section 3.1.4, the detection limits associated with
such instrumentation vary significantly. Generally, detection limits are system specific and are
not constant. Detection limits are derived as part of the calibration procedures and take into
account an anticipated mix of radionuclides, sampling flow rates, and the response characteristics
of the radiation detectors or analytical methods.
3-15
-------
3.1.3 Indirect Radiation Monitoring Methods
Stack samples need not always be monitored in a real-time mode. In fact many institutional
incinerators rely on manual monitoring methods which are implemented for individual burns
(C0081, EGG82, LAN83, WM85). Samples are collected using a simple pump and^ sample
collection device or elaborate systems as described above. Once collected, the sample is
processed and analyzed in a laboratory. Radioanalytical procedures may employ a wide range
of methods, including gross alpha and beta counting, gamma, x-ray, or alpha spectroscopy, and
liquid scintillation counting (ACG78, NCR78). The selected analytical methods must be
implemented in accordance with good laboratory practices and comply with established
standards. There are well-documented procedures for analyzing stack samples (DOE83, EPA84,
NCR78, EPA89). The selection of a measurement method, given a specific application, is based
on such considerations as sample physical and chemical forms, anticipated range of sample
radioactivity, radionuclide(s) of interest, analytical frequency, specified or desired lower limit
of detection, availability of time and resources, and costs. In general, radiochemical analyses
are similar to classic wet chemistry procedures, except that the mass of the radionuclide(s) is
usually so small that conventional volumetric or gravimetric methods are not capable of
separating the radioactivity. The procedure, instead, relies on measuring the amount of
radioactivity which is emitted by the sample.
The radionuclide of interest, in its elemental form, may be separated from the sample matrix by
chemical extraction, precipitation, ion-exchange, electrolysis, distillation, and chromatography.
In other instances, it may simply be necessary to reduce the sample volume or mass by
evaporation, wet ashing (using, for example, nitric acid), dry ashing at low or high temperature,
or acid fluxes in order to prepare a sample for analysis. In any case, the selection of a specific
method must ensure that losses are minimized and quantifiable. It is common practice to
introduce a tracer element (stable or radioactive) to determine sample chemical recovery or
yield.
3-16
-------
Regardless of the method chosen, some common factors must be considered. The major factors
are:
a. Sample - Samples are analyzed using a procedure that stipulates sample size, volume,
and counting geometry or configuration. When analyzing alpha, beta, and x-ray
emitters, corrections must be made for sample self-absorption. Depending on the mass
and matrix of the sample, some of the radioactivity originating from the center of the
sample will not escape and, consequently, will not be detected and measured. Such
corrections are made empirically, or by using a sample with a mass which results in little
or no self-absorption. Usually, the sample mass is characterized as density thickness,
expressed in units of milligrams per square centimeter (mg/cm2). The density thickness
is used to correct for self-absorption for a given type of particle emission and its energy.
b. Sample Handling - All samples must be handled with care to prevent any accidental
loss of sample material or cross-contamination of the counting equipment and laboratory
work areas. Cross-contamination may cause erroneous conclusions. If a sample were
actually free of any radioactivity, any cross-contamination (e.g., from another sample)
would lead to the conclusion that the sample did contain some radioactivity. Preventing
sample losses during handling is also important because any loss would result in
underestimating the actual levels of radioactivity. Accordingly, all samples must be
properly prepared for analysis.
Samples are typically contained in or on planchets, kept in solution in colloidal or
dissolved forms, electro- or flame-deposited on metal discs, or fixed on filter paper.
c. Instrumentation - Instrumentation must be selected to ensure that the radiation
detection principle applied will indeed detect and measure the radionuclide(s) of interest.
The operational features of the instrument must be well known, considering system
background count-rate, sample size or volume, calibration, counting gas, counting
efficiency, counting time, counting geometry, decay correction factors, and lower limit
3-17
-------
of detection. Given that the system has been calibrated, it is also necessary to verify
system settings, such as high voltage, energy gain, upper and lower level discriminator,
dead-time, counting gas flow rate, background and standard count-rates, and operational
stability.
3.1.4 Instrumentation Detection Limits
The use of a continuous stack sampling and monitoring system requires that the response
characteristics and detection limits be known. Table 3-1 summarizes the responses of several
commercial systems. It should be noted that these systems were not designed for use on
incinerators, and none have been installed on incinerators. The response characteristics of the
system are keyed, by calibration, to a specific radionuclide(s) which is used to determine release
rates and concentrations. Other radionuclides that are not detected by the monitoring system or
are beyond the range of sensitivity are inferred by scaling factors. The scaling factor is
sometimes established beforehand based on radioanalysis of the waste before incineration.
Another method used to derive the scaling factor relies on the known radiological characteristics
of the process stream from which the waste originates. This approach works best for waste
streams which are homogeneous with well-characterized radionuclide distributions and
concentrations. This method is particularly well-suited to liquid waste streams; e.g.,
contaminated oils, machining fluids, and liquid scintillation fluids.
For some radionuclides, as noted earlier, it is not possible to rely on continuous monitoring.
This is the case for tritium and C-14, for example, since there is no known reliable method to
measure either in real-time. The problem is compounded by the difficulty in determining the
presence and concentrations of tritium or carbon-14 in some specific waste streams. This is
particularly true for solid and bulk waste material but not for liquid wastes.
Depending on the sophistication of the continuous monitoring system, there is a need to
determine, a priori, the minimum detectable concentrations (MDC) that the monitor will reliably
measure. The concept of the MDC, also referred to as the lower limit of detection (LLD),
3-18
-------
Table 3-1. Summary of Stack Monitoring System Response(a)
Vendor
Sorrento:
Ludlum:
Model or
System
RD-56B
RD-59
Dual Channel
Dual Channel
Beta Air
Monitor 333-2
Iodine Air
Monitor 377
Type(b) of
Detector
B-Scint.
NaI(Tl)
B-Scint.
A-Scint.
GM Tube
NaI(Tl)
Sensitivity(c)
Value Nuclide
10-12
10-12
10-11
10-11
10-11
10-11
Part.
1-131
Sr-90
Am-241
Sr-90
1-131
Notes(d)
@ 3 SCFM
it ll
It ll
ll ll
@ 2 SCFM
Victoreen:
Gaseous Effl.
Monitor 940-1
NaI(Tl)
B-Scint.
10-12
10-9
EG&G-Ortec
Berthold: LB-150D
LB-151-1
LB-IIO
LB-IIO-A
Eberline:
AMS-3
Alpha-VIA
Gas Prop.
B-Scint.
Gas Prop.
Ion Cham.
GM Tube
Surface
Barrier
10-13
10-11
10-9
10-5
10-12
10-12
1-131
Cs-137
1-131
1-133
Gross
B-/Alpha
Gross B-
H-3/C-14
H-3
Tc-99
Pu-239
4 SCFM
3 SCFM
2 SCFM
(a) Data collected from vendors by telephone or technical brochure summaries.
(b) Detector systems: HPGeLi, high purity germanium-lithium semiconductor; B-Scint., beta
particle plastic scintillator; A-Scint., alpha particle plastic or silver activated zincsulfide
scintillator; NaI(Tl), thallium-doped sodium iodide scintillator; GM Tube, Geiger-Mueller
detector tube; Gas Prop., flow-through gas proportional detector; Ion Cham., flow-through
ionization chamber; Surface Barrier, diffused-j unction solid state surface barrier detector.
(c) Expressed in uCi/mL, e.g., 10-13 equals 1.0 x 10-13 uCi/mL.
(d) Nominal or typical values, actual flow rates may vary.
3-19
-------
Table 3-1. Summary of Stack Monitoring System Response(a), Cont'd
Model or Type(b) of
Vendor System Detector
SAIC Stack Isotopic HPGeLi
Monitoring Syst.
11
n
ii
n
11
n
n
ii
it
it
»
H
it
tf
n
it
it
II
.
Sensitivity(c)
Value Nuclide Notes(d)
10-13
10-10
10-9
10-10
10-10
10-11
10-10
10-9
10-10
10-8
10-13
10-10
10-10
10-9
10-10
10-11
10-11
10-10
10-10
10-10
Part. @ 2 SCFM
Mn-54 " "
Cr-51 " "
Co-58 " "
Fe-59 " "
Co-60 " "
Sr-91 " "
Sr-92 " "
Mo-99 " "
Tc-99m
1-131 " "
1-132 " "
1-133 " "
1-134 " "
1-135 " "
Cs-134 , " "
Cs-137 " "
Cs-138 " "
Ba-140 " "
Ce-141 " "
(a) Data collected from vendors by telephone or technical brochure summaries.
(b) Detector systems: HPGeLi, high purity germanium-lithium semiconductor; B-Scint., beta
particle plastic scintillator; A-Scint, alpha particle plastic or silver activated zincsulfide
scintillator; NaI(Tl), thallium-doped sodium iodide scintillator; GM Tube, Geiger-Mueller
detector tube; Gas Prop., flow-through gas proportional detector; Ion Cham., flow-through
ionization chamber; Surface Barrier, diffused-junction solid state surface barrier detector.
(c) Expressed in uCi/mL, e.g., 10-13 equals 1.0 x 10-13 uCi/mL.
(d) Nominal or typical values, actual flow rates may vary.
3-20
-------
addresses a procedure for determining the smallest amount of sample activity that will yield a
net count rate for which there is confidence, at a predetermined level, that the activity is due to
the sample rather than background (NCR78, DOE83, TS083).
Counting a radioactive sample or background will yield a series of measurements (which should
be distributed as a Poisson distribution) from which it is possible to establish the standard
deviation from a single measurement. The standard deviation can then be manipulated in the
same way as the Gaussian standard deviation to establish a confidence interval about the mean.
If a background count-rate and its associated standard deviation are established, this information
can be used to derive a lower limit of detection. For example, a sample count one standard
deviation above background would indicate the presence of activity in the sample 84 percent of
the time and false positives 16 percent of the time. If two standard deviations were used instead,
the presence of radioactivity would be detected 97.5 percent of the time, and 2.5 percent of the
time one would note false positives. Since the sample and background count rates have their
own distributions, the interaction of the two distributions becomes important as the sample
activity tends to approach background levels. When the total sample count approaches
background, the distributions overlap such that it becomes difficult to discern the difference in
radioactivity due to the sample from that due to background. The count rate that establishes the
lower limit of detection is defined by the overlapping region of both distribution curves.
Several factors can be controlled to enhance the detection limit for a specific measurement
method. Since the goal is to detect and reliably measure low radioactivity levels in the sample,
the detector must be located in an area of low background radioactivity (including both ambient
external radiation exposure rates and airborne concentrations). Some types of detectors are very
insensitive to external radiation and accordingly do not pose a problem in this regard. For
continuous air sampling systems, especially those designed to measure alpha radioactivity, the
problem is compounded by the presence of naturally occurring radioactivity; i.e., decay products
from radon (radon-222) and thoron (radon-220) due to the uranium and thorium decay chains,
respectively. Depending on the type of instrumentation and data/spectra reduction method used,
such systems may resolve overlapping alpha spectra and reject the contribution due to radon-
3-21
-------
thoron decay products. As will be discussed later, the presence of radon decay products can
complicate the interpretation of results generated by stack monitoring systems.
Radon gas decays into paniculate daughter products, which are retained on sampling filters. The
decay products, being themselves radioactive, decay and cause an ingrowth in activity,
eventually reaching an equilibrium with that of the first member of the decay chain. The
concentrations of radon decay products are rarely at equilibrium with their parent gas.
Typically, the decay products are separated and are present at a fraction of the equilibrium,
about 30 to 80 percent (NCR75). The typical outdoor radon-222 concentration is about
200 pCi/m3 and 5 pCi/m3 for radon-220 (NCR87). Accordingly, decayproduct concentrations
are always less than that of radon. The ambient concentrations of radon and its decay products
are known to vary by a factor of 10, depending on atmospheric pressures, temperature, soil
moisture, and temperature inversions. Typical diurnal variations cause radon concentrations to
peak early in the morning and drop off sharply in the afternoon (NCR87).
If, for example, stack emissions include americium-241 or plutonium-239, the instrumentation
must be able to discern the presence of radioactivity due to all radionuclides that decay by
emitting alpha particles. If the system relies on gross alpha counting methods, the detector will
not discern the different radionuclides. The results, expressed as total count rate, will represent
the sum total of the radioactivity retained on the filter and seen by the detector.
If, however, the system relies on alpha spectroscopy, the detector will segregate alpha emissions
and identify each radionuclide. Americium-241 decays by emitting 5.5 MeV alpha particles,
plutonium-239 emits 5.1 MeV particles, and the radon decay products emit several particles
ranging from 6.0 to 7.7 MeV (KOC81). (Only the major alpha emissions are cited here.) The
count rate associated with the detection of each alpha particle is stored in its respective energy
channel. Because of the random process of radioactive decay and interaction of alpha particles
with the detector, the presence of a radionuclide is represented by a series of Gaussian
distributions, one for each alpha particle. These emissions may result in overlapping spectra,
depending on the system's resolution. The respective contribution of one spectrum into another
3-22
-------
spectrum would have to be resolved either manually or via an algorithm. The system's energy
response is typically divided into regions-of-interest, each one identifying the presence of a
radionuclide. By using calibration methods, the response of one radionuclide in the region of
interest of another radionuclide is determined empirically or is mathematically fitted based on
a few measurements. These relationships are noted and used to develop a matrix and set of
simultaneous equations to calculate the true count rate and radioactivity associated with each
nuclide.
For illustration purposes, it is worthwhile to compare current maximum permissible
concentrations (MFCs) for plutonium-239 and americium-241. The Nuclear Regulatory
Commission's MFC for plutonium-239 is l.OxlO'12 uCi/mL and 4.0xlO'12 uCi/mL for americium-
241. Both MFCs are for insoluble forms based on 10 CFR 20, Appendix B, Table II, Col. 1
values for nonoccupational exposures. For the radon-222 and radon-220 concentrations noted
above, the corresponding radon decay product concentrations are I.Oxlfr10 and 2.5xlQ-12 uCi/mL,
respectively, assuming 50 percent equilibrium. When compared to the MFCs, it can be seen
that plutonium-239 and americium-241 concentrations fall within the range of radon decay
products normally encountered in environmental settings.
For continuous stack monitor operation under such conditions, the system, starting with a new
filter, will show a rapid rise in the count-rate, followed by a plateau which represents an
equilibrium between two competing factors, 1) the accumulation of radon decay products on the
filter media and 2) radioactive decay of radon progenies. Occasionally, the plateau would rise
and fall, depending on changes in ambient radon concentrations, filter dust loading, and
sampling flow rate. If the alarm trip points are set at some fraction of the MFC, which is
usually the practice, the monitoring system would most likely generate spurious alarms
coinciding with variations and increases in ambient radon decay product concentrations. The
cause for these alarms would be investigated to determine whether or not the alarm is the result
of spurious responses, due to some instrument malfunction, or real. The particulate filter would
be removed and subjected to several laboratory analyses to identify the radionuclides. In order
to confirm the presence of naturally occurring radioactivity, one of the steps would involve
3-23
-------
counting the filter at specific time intervals to observe the radioactive decay of the radon
progenies. Since americium-241 and plutonium-239 are both long-lived radionuclides, repeated
analyses showing short-lived radon progenies would be indicative that the alarm was caused by
naturally occurring radioactivity and not due to the operation of the incinerator.
Other factors may enhance the response characteristics of a stack sampling and monitoring
system. Such factors include selecting a type of detector which offers energy optimal response,
properly determined sampling flow rate, and short instrumentation response time. The sampling
flow rate is governed by two considerations. First, the flow rate should be such that it ensures
isokinetic sampling (discussed in greater detail above). Second, the flow rate should be
sufficiently high to meet the desired MDC objectives, given an established sampling frequency.
Ideally, longer sampling times provide lower MDCs.
The selection of the detector media and associated electronics (analog-todigital converter (ADC))
generally dictates the overall response characteristics of the system. For spectroscopy systems,
the ADC dead-time will depend on the amount of activity presented to the detector. The dead-
time refers to the time during which the instrument is busy converting and storing data in a
digital form and is not acknowledging any additional pulses from the detector. For the intended
uses, dead-times should typically be low (a few percent) and result in no significant data loss.
These losses are compensated by operating the system with the clock set to "live-time" which
automatically corrects for the dead-time.
Instrumentation can also be equipped with algorithms that automatically perform energy
calibrations, reduce spectra and data, and provide the means to subtract or reject count-rates due
to background radioactivity. These features generally facilitate interpretation of the data and
results as well as system operation. The problem with "canned" software/firmware packages
is that, as black boxes, they offer little understanding as to how the data are handled and
reduced. Vendors treat this information as proprietary, providing little or no additional
documentation other than that provided in the manuals. Consequently, it may be difficult or
even impossible actually to determine how the raw data (from a count-rate, in cpm) is converted
3-24
-------
to the proper radiological units (in uCi/mL or uCi/s). It is good radiological practice to
generate, using first principles, data and results manually during the initial calibration
procedures. The calibration test results and any associated calculations should be documented
and maintained as permanent records.
3.2 RADIATIONPROCESSMONITORINGTECHNOLOGYDESCRIPTION PRINCIPLE
OF OPERATION, AND APPLICATIONS
Real-time radiation monitoring systems can be used to warn the operator that certain conditions
are rapidly changing, to trip audiovisual alarms, or to activate some components. Typically,
sampling system trips issue warnings before terminating a process or isolating a component,
thereby giving the operator time to respond (IAE89, BAT83, NRC86, AER84). In some cases,
the monitor could automatically terminate the burn if the detected conditions would result in
unsafe consequences or cause releases to exceed established limits. For example, a sudden rise
in stack airborne radionuclide concentrations could indicate a massive failure of the off-gas
treatment system or the introduction of waste at unacceptably high concentrations.
In other instances, two or more incinerator process parameters may be fed into a logic circuit
to establish operating conditions that should warrant termination of the burn. For example, a
sudden loss of differential pressure across a HEPA filter bank and an immediate rise in
radionuclide concentrations or release rate would indicate a massive HEPA filter bank failure.
Given this scenario, the burn should be terminated as quickly as possible. Whether or not the
radiation monitoring system should directly terminate the burn must be weighed against the
potential consequences that this action could have on the incinerator itself. A sudden rather than
a controlled cooldown could irreversibly damage the refractory lining, warp some internal
components, or cause slagging solidification in certain parts of the combustion chamber and ash
receiver (IAE89, C0081). A more appropriate action might be to stop introducing additional
waste in the combustion chamber. For waste in a solid form, the action would involve shutting
down the ram or conveyor feeding the material to the incinerator. For liquid wastes, the process
would simply involve shutting down the injection pump. Following these actions, the incinerator
could then be brought to a controlled shutdown.
3-25
-------
For incinerators with elaborate off-gas treatment systems, the stack monitor could be used to re-
route exhaust emissions to standby HEPA filters. In this scenario, the alarm trip would cause
one damper to close and another to open. Such actions could be performed without upsetting
in operating conditions and would provide time to evaluate the event, its causes, and necessary
corrective actions.
3 3 APPLICABILITY OF NONRADIOACTIVE EMISSIONS STACK MONITORING
METHODS TO RADIONUCLIDES
As noted above, some sampling methods identified by the Environmental Protection Agency to
demonstrate compliance with the Clean Air Act (EPA89) are useable with little or no
modification (AMB86, INC89, BUN89). In principle, many of the sampling train components
are identical. The only difference revolves around the specificity of the pollutant being collected
or analyzed. In some cases, especially for some volatile organic compounds, the methods may
not always be compatible with one another. For example, if an impinger uses a solution that
enhances the absorption of a specific compound and it is also required to determine the
concentrations of tritium and carbon-14 via liquid scintillation counting, the impinger solution
could affect the photochemical luminescence process of the scintillation cocktail (OPP87,
NCR78, ACG78). The chemical could quench the scintillation process, thereby falsely
indicating that there is no tritium or carbon-14. Conversely, the impinger solution could
enhance the photochemical luminescence process and erroneously indicate very high tritium and
carbon-14 concentrations.
Another important difference revolves around the analytical procedures for determining the
presence of radioactivity. If a real-time monitoring system is used, sample collection and
processing are conducted under vastly different conditions than samples collected to characterize
the presence of organic compounds or metal oxides. In many radiation sampling systems, the
sample may not be readily recoverable or, if it is, the sample may no longer represent actual
conditions. This is the case for volatile organic compounds which may collect on paniculate
filters. In time, an equilibrium may be achieved between the sample collection rate and the
3-26
-------
evaporation rate, but it may still be impossible to determine reliably the equilibrium ratio. This
problem is further compounded by the presence of additional organic vapors which may compete
for collection and retention sites, thereby upsetting the equilibrium. Finally, as more particulates
are retained on the filter paper, the presence of solids may further upset this equilibrium.
A similar problem exists with the use of activated charcoal traps or cartridges. The presence
of organic vapors may poison adsorption sites, causing a breakthrough to occur and rendering
the charcoal incapable of capturing or retaining organic vapors or radioiodines. In this example,
degradation of activated charcoal cartridges or traps interferes with both radiological and
nonradiological characterization of air emissions. The installation of the sampling train and the
sequence of filters, charcoal cartridges or traps, and impingers must be designed in anticipation
of the pollutants being measured. In some instances, it may be necessary to establish redundant
sampling trains, one to characterize radionuclide emissions and the other for organic compounds.
This approach was used in conducting the tests and burn trials of the fluidized bed incinerator
at the DOE's Rocky Flats Plant (DOE86).
3.4 MONITORING RADIONUCLIDE CONCENTRATION IN INCINERATOR ASH
There are no instruments currently available for direct assay of alpha, beta, and gamma emitting
radionuclide concentrations in ash receivers. Direct assay research on power plant waste
indicates that two instrumentation techniques may be applicable to ash assay (EPRB7).
Collimated, calibrated gamma spectrometer measurements in combination with predetermined
scaling factors for difficult-to-measure nuclides can be used to quantify the gamma-emitting
nuclides in a waste form. Passive neutron counting technology, based on surrounding the waste
form with neutron detector tubes encased in moderator material has been used to measure TRU
content of power plant radioactive wastes. Neither of these techniques have been evaluated for
use on incinerator ash.
Initially, the hot ash must be cooled after it is removed from the incinerator. Some incinerators
are equipped with ambient radiation monitoring equipment, but such systems are installed only
3-27
-------
for occupational radiation protection purposes (IAE89, NRC86,1ER88, AER84). Some facilities
are also equipped with ambient airborne concentration monitors, again for the purpose of
radiation protection, since ashes could become airborne in immediate work areas and
subsequently be inhaled by workers.
The normal practice is to collect ashes manually and perform the necessary radiological arialyses.
Ash sample analyses are conducted by methods similar to those described earlier. The
processing of ash samples may involve chemical extraction, sample weighing, and sample
splitting (NRC83). Radioanalytical procedures may include a wide range of methods, including
gross alpha and beta counting, gamma, x-ray, or alpha spectroscopy, and liquid scintillation
counting (NCR78). Because ash samples are usually high in specific activity, the radioanalytical
time (i.e., sample counting time) may be reduced. Ash with high specific activity also allows
the use of smaller sample sizes, thereby facilitating sample processing and minimizing the
volume of analytical waste. As before, the selected analytical methods must be implemented in
accordance with good laboratory practices and must comply with established regulatory standards
or criteria.
Ash may also be subjected to other types of tests, for example TCLP toxicity, to demonstrate
whether or not the ash is a hazardous material. If the ash is radioactive, it may have to be
disposed of as radioactive waste and meet established waste acceptance criteria in terms of
radionuclide concentrations, presence and concentration of transuranic radionuclides, nuclear
criticality safety, and decay heat loads (EGG88). Such waste acceptance criteria require that the
physical and radiological properties of the ash be assessed to identify the proper disposal
method. Analyses may in part reflect Department of Energy, State, and Federal standards
(DOE89). For example, the analyses must characterize free standing liquids, chelating agents,
explosive, reactive, flammable, or pyrophoric materials, generation of toxic fumes or vapors,
and internal pressures.
For ash that has been stabilized by cement or other solidification media, the analyses must show
that the radioactivity will not leach out of the media for the anticipated disposal conditions. It
3-28
-------
also must be demonstrated that the solidification media will not degrade or crumble, given
disposal depths and pressures, presence of water, microbial activity, and radiation- or chemically
induced internal changes or degradation. Analyses are typically conducted under an established
set of procedures. If the ash is to be solidified before disposal, samples are first solidified on
a bench scale. Once the solidified ash samples have fully cured, several tests are conducted to
verify the behavior and properties of the solidified samples. The test results are documented and
compared to the waste acceptance criteria to determine whether or not the solidified samples are
in compliance. If the criteria have been met, the process is scaled up and applied to the bulk
ash volume.
3-29
-------
Chapter 3 References
AER84 Aerojet Energy Conversion Company; Mobile Volume Reduction System, Topical
Report No. AECC-4-NP-A, prepared for the Nuclear Regulatory Commission,
Sacramento, CA, November 4, 1984.
ACG84 American Conference of Industrial Hygienists; Industrial Ventilation, 18th
edition, Cincinnati, OH, 1984.
ACG78 American Conference of Industrial Hygienists; Air Sampling Instrumentsfor
Evaluation of Atmospheric Contaminants, 5th edition, Cincinnati, OH, 1984.
AMB86 Ambrose, M.L.; National Emission Standards for Hazardous Air
PollutantsCompliance Verification Plan for the K-1345 Toxic Substances Control
Act Incinerator, Martin-Marietta Energy Systems, Oak Ridge National
Laboratory, Oak Ridge, TN, K/HS-109, July 28, 1986.
ANS69 American National Standard; Guide to Sampling Airborne Radioactive Materials
in Nuclear Facilities, ANSI N13.1-1969, New York, NY, 1969.
BAT83 Battelle Columbus Laboratories; Safety Related Information for the Volume
Reduction Demonstration Facility, BCL-1801, (Rev. 3,12/16/86) Columbus, OH,
August 15, 1983.
BUN89 Bun, D.H.; Continuous Off-Gas Sampling System, Martin-Marietta
EnergySystems, Oak Ridge National Laboratory, Oak Ridge, TN, RQT-276,
March 1989.
C0081 Cooley, L.R.; Current Practices of Incineration of Low-Level Institutional
Radioactive Waste, EG&G, Idaho, Inc, EGG-2076, February 1981.
DOE83 Department of Energy; EML Procedures Manual, Environmental Measurements
Laboratory, New York, NY, HASL-300, 26th Edition, 1983.
DOE86 Department of Energy; Rocky Flats Plant Fluidized Bed Incinerator TestPlan,
Sampling Locations and Procedures, Appendix 4, Section D-5b (2)(c), p. D-4-31,
Document No. C07890010526, November 28, 1986, Rev. N. 0.
DOE89 Department of Energy; Integrated Data Base for 1989: Spent Fuel andRadioactive
Waste Inventories, Projections and Characteristics, DOE/RW-006, Rev. 5,
November 1989.
3-30
-------
EGG82
EGG88
EPA84
EPA89
EPR87
IAE89
INC89
IRU_
KOC81
KUR_
LAN83
NCR87
NCR75
Radioactive Waste Incineration at Purdue University, EG&G, Inc.Idaho National
Engineering Laboratory, DOE/LLW-12T, November 1982.
Informal Report: Low-Level and Mixed Waste Incinerator Survey Report,EG&G,
Inc. Idaho National Engineering Laboratory, EGG-LLW-8269, October 1988.
Environmental Protection Agency; Radiochemistry Procedures Manual, Eastern
Environmental Radiation Facility, EPA 520/5-84-006, Montgomery, AL, Aug.
1984.
Environmental Protection Agency; Final Rule and Notice of Reconsideration,
NESHAPS for Radionuclides, Appendix B to 40 CFR 61, FR Vol.54, No. 240,
51654 - 51715, December 15, 1989.
Electric Power Research Institute; Advanced Radioactive Waste Assay Methods,
EPRI NP-5497, November 1987.
International Atomic Energy Agency; Treatment of Off-Gas from Radioactive
Waste Incinerators, Technical Reports Series No. 302, Vienna, 1989.
The 1989 Incineration Conference; Incineration Basics Course, May 2, 1989,
KnoxvilleTN.
Irujo, MJ. and Bucci, J.R.; Savannah River Plant LLW Incinerator:
Operational Results and Technical Development.
Kocker, D.C.; Radioactive Decay Data Tables, Department of Energy,
DOE/TIC-11026, 1981.
Kurz Instrument, Inc.; Mass Flow Sampling and Isokinetic Systems, Monterey,
CA, undated document.
Landolt, R.R.; Evaluation of a Small, Inexpensive Incinerator for Institutional
Radioactive Waste, Health Physics, Vol. 44, No.6, pp.671675, June 1983
National Council on Radiation Protection and Measurements; Exposure ofthe
Population in the United States and Canada from Natural Background Radiation,
NCRP Report No. 94, issued Dec. 30, 1987.
National Council on Radiation Protection and Measurements; NaturalBackground
Radiation in the United States, NCRP Report No. 45, issued Nov. 15, 1975.
3-31
-------
NRC86 Nuclear Regulatory Commission; Safety Evaluation Report Related to theVolume
Reduction Services Facility, Babcock & Wilcox, Parks Township, PA, Docket
70-364, April 1986.
NRC83 Nuclear Regulatory Commission; Incineration of a Typical LWR Combustible
Waste and Analysis of the Resulting Ash, NUREG/CR-3087, Battelle Pacific
Northwest Labs, May 1983.
NCR78 National Council on Radiation Protection and Measurements; A Handbook
ofRadioactivity Procedures, Report No. 58, Washington, DC, November 1, 1978.
OPP87 Oppelt, E.T.; Incineration of Hazardous Waste - A Critical Review, JAPCA,
Vol. 37, No.5, May 1987, pp. 558-586.
SAI85 Science Applications International Corporation; Stack Isotopic Monitoring System
- Application and Technical Specifications, San Diego, CA, November 1985.
SEG_ Diagram from Mr. Bud Arrowsmith (Scientific Ecology Group) to Mr. Larry Coe
0 April 9, 1990.
SOR89 Sorrento Electronics, Inc.; Dual Alpha/Beta Fixed Filter ParticulateRadiation
Monitors for Plant 8 - USDOE Fernald, Equipment Manual, E-1151416, San
Diego, CA, December 1989.
TER88 Terrell, M.S.; Incineration Test Results of a Fluidized Bed IncineratorSystem,
Duke Power Company, Radwaste Engineering, Charlotte, NC, March 31, 1988.
TS083 Tsoulfanidis, N.; Measurement and Detection of Radiation, McGraw-Hill, New
York, 1983.
VIC Victoreen Inc.; Off-Line Gaseous Effluent Monitors - Systems Descriptions and
Applications, Cleveland, OH, undated document.
WM85 Swearingen, F.L Van; Waste Management 1985; Incineration of Microspheres,
Tuscon, AZ, March 1985.
3-32
-------
4. Consideration of Incinerator Accident and Abnormal Operation Scenarios
Consideration of incinerator accident/abnormal operations scenarios, their consequences, and the
options available to prevent or mitigate such events is important to ensure protection of the
public and workers from potentially harmful exposure due to releases of materials processed at
the incinerator. Potential incinerator-related accidents include the following:
Fires and Explosions
Fires during transportation, accumulation, and storage of incompatible material
Fire in waste (feed) material preparation
Catastrophic incinerator failure; e.g., explosions of a severity sufficient to cause
failure of the combustion chamber
Emissions Control Feature Failure
Filter failures
Vent pipe failures
Off-gas treatment system failures
Acts of Nature
Earthquakes
Tornadoes
Flooding
Transportation Accidents
Loss of Essential Utilities
Loss of power
Loss of water to scrubbers and for quenching ash
Many of the potential hazards are not associated solely or even primarily with the actual
operation of the combustion process but rather with one of three broad stages of incinerator
operation: the gathering, storage, and handling of the incinerator feed material, the
treatment/release of effluent gases, and the handling, storage and disposal of liquid and solid
4-1
-------
effluents. Usually the potential for the largest releases of radioactive or hazardous materials falls
into one of these stages.
Determination of which specific accidents pose the greatest threats, and what process or emission
controls could be used for prevention/mitigation, can only be done on a case-by-case basis using
the actual design characteristics and operating conditions of a proposed incinerator to generate
an assessment of possible accident scenarios and associated impacts for each individual situation.
For example, the characteristics of the feed material (e.g., solid or liquid, Btu content, chemical
form) and the method of its storage (tanks, building equipped with fire detection capability and
sprinklers, etc.) can significantly affect the likely accident scenarios. As noted earlier in this
report, successful incineration of waste material depends on a relatively uniform and consistent
waste feed. Considerable attention must thus be given to feed preparation. On the other hand,
the nature of hazardous and mixed wastes is such that there is a considerable incentive to
minimize any additional handling after the waste has been generated. This poses a dilemma for
the designers and operators of waste incinerators. In practical applications, considerable
variation in feed materials may be present. The following wide range of waste types intended
for incineration as mixed waste at one proposed facility (LLNL) illustrates the potential for
abnormalities caused by nonuniform waste feed.
chlorinated and other organic solvents 25 %
oils and greases 20%
oil/water and other organic/water mixtures 28 %
organic sludges and still bottoms 3%
low-level radioactive solids and containers 17%
nonradioactive solid waste 7%
Range of btu values per Ib: 650 - 18,000
Percent range of water content: 0-90 percent
As a second example, the design of the off-gas treatment system must be evaluated (what is the
sequence of the treatment stages; e.g., are the gases adequately cooled and dried before reaching
HEPA filters, or, if the off-gas filters fail will building ventilation filters provide backup
4-2
-------
protection). Filtering of off-gases is typically a combination of an aqueous scrubber to cool the
exhaust and neutralize and remove acidic compounds followed by a HEPA filter, possibly
supplemented by a charcoal filter to capture organic vapors and iodine. Total or partial loss of
effective filtering capacity could result in releases of mixed waste particulates, including heavy
metals and iodine-131. It is important that there be real-time monitoring of the performance of
the HEPA filters and other emission control devices to ensure they are operating at peak
efficiency.
HEPA filters are the most common air pollution control device for particulates used in the
nuclear industry. Probably the most critical component in controlling radioactive emissions,
HEPA filters are essentially delicate structures. They can sustain structural damage relatively
easily under conditions of higher-than-designed-for rates of airflow, shock waves (for example,
as a result of explosions in the incinerator), higher-than-designed for temperatures, excess
humidity, and excess paniculate deposits.
A review of the incinerator proposed for LLNL, for example, noted that the HEPA filters
designed for controlling the off-gases would be subject to failure as a result of moisture buildup,
temperature and pressure surges unless major design changes, including the installation of a
prefilter, were implemented (BER88). The emission control system at the Los Alamos CAI is
equipped with a quench tower to cool the hot exhaust gases, followed by a wet alkaline scrubber
to remove chloride and other acidic gases after which a condenser should remove most free
liquid. The dried exhaust is ducted to the HEPA filter. Because the filter medium is made
primarily of paper that would be severely weakened by exposure to water, it is important that
essentially no moisture be allowed to reach the HEPA filters.
New high strength HEPA filters reportedly have been developed in Europe that appear to have
a much greater capacity for withstanding adverse conditions such as excess heat and humidity
or high air flow. These filters are being manufactured by European firms and are being installed
in German nuclear facilities (BER88).
4-3
-------
Finally, as a third example, the storage and handling of the solid and liquid effluents must be
reviewed (e.g., could an accident or human factor result in a release from a line or tank that
would release radioactive or toxic scrubber liquors to the environment or release dry ash to the
atmosphere). Tanks containing feed material typically are equipped with vent pipes. Bulk
storage units also contain pressure relief valves. Failure of these components could result in
material being vented directly to the atmosphere without passing through the filtration system.
4.1 EXAMPLE ANALYSES OF INCINERATOR ACCIDENT SCENARIOS
As noted earlier, the specific design parameters and operating conditions of each incinerator, in
relation to the range of radioactive and mixed waste it is intended to burn, must be analyzed to
determine likely accident scenarios and evaluate their consequences. The descriptions that
follow summarize analyses that have been performed for several incinerators described in
preceding chapters. These cases are used here only as examples. Subsequent changes in design
or operating conditions at the incinerators for which they were developed may have altered the
likelihood or consequences of any given scenario, however, they serve to illustrate the wide
variations that can occur in accident scenarios and 'consequences.
4.1.1 Scientific Ecology Group (SEG)
In its NESHAPS permit application to the EPA, SEG evaluated the radiological impact of two
major accidents: (1) the failure of the heat removal system resulting in thermal destruction of
the flue gas filtration system and subsequent release of unfiltered radioactive ash to the
environment, and (2) a pressure excursion in the incinerator resulting in rupture of the pressure
release diaphragm, release of ash to the incinerator building, and partial ash release to the
environment (SEG88). These accidents were evaluated for radiological impact on the
environment by determining the approximate radioactive release to the environment and
determining the resulting dose by comparison to previous AIRDOS-EPA runs. The following
descriptions are quoted from the NESHAPS application.
4-4
-------
"FAILURE OF THE HEAT REMOVAL SYSTEM - If feed water to the heat
removal system were to fail catastrophically and the incinerator could not be
cooled to less than 400 degrees Fahrenheit before baghouse and HEPA filter
destruction occurred, the radioactive ash inventory (up to about 5 kg) trapped on
the filters would be released. Within 4 minutes the emergency cool-down system
would cool the incinerator to less than 400 degrees Fahrenheit and the redundant
filtration system would be switched in. Even if the redundant filters could not be
used, the system ventilation could be stopped at about 400 degrees Fahrenheit and
further releases would cease. Besides the radionuclide inventory trapped on the
bag filters and HEPA filters, a much smaller quantity of additional unfiltered
radioactivity in flue gases would also be released. Five kilograms of ash have
about the same radionuclide content as one year of routine releases except that the
iodines, technetium, carbon, and tritium would not be present in the ash, having
already been released routinely."
"PRESSURE EXCURSION IN THE INCINERATOR - If a transient
overpressure condition occurred such that the pressure release door near the top
of the incinerator gave way, a small amount of ash would be blown into the
incinerator building, perhaps as much as a few kilograms. To a large extent, this
ash would be contained in the building and could create a temporary airborne
condition for workers. However, since the plant ventilation is also HEPA
filtered, essentially no release to the environment would occur. It should be
noted that significant overpressure can only be caused by explosive materials such
as large oxygen bottles. The SEG sorting process described elsewhere in this
document eliminates this possibility."
SEG determined that the failure of the heat removal system would result in a site boundary (100
meter) whole-body dose of less than 0.1 mrem and a thyroid dose of less than 0.3 mrem. SEG
estimated that essentially no release to the environment would occur as a result of the pressure
4-5
-------
excursion accident. For comparison, the following annual doses were calculated (again using
AIRDOSEPA) for routine operations.
Distance
(meters)
100
200
300
500
800
1300
1800
Whole Body Dose
(mrem)
2.3
1.2
0.8
0.5
0.4
0.3
0.26
Thyroid Dose
(mrem)
17
9
6
3.8
2.7
2.1
1.7
SEG noted that these doses fall well within the required EPA limits of 25 mrem/yr (whole body)
and 75 mrem/yr (critical organ), and are substantially below the approximately 120 mrem/yr
whole-body dose from natural background for that area.
4.1.2 Rocky Flats
In 1987 the Colorado Department of Health (CDH) prepared a preliminary public health risk
assessment for the radioactive component of proposed trial burns at the DOE Rocky Flats Plant
mixed waste fluidized bed incinerator (COL87). One maximum "credible" accident scenario and
one "incredible" accident scenario were analyzed. Both depleted uranium and weapons grade
plutonium were slated to be used in the trial burns. The proposed trial burns did not take place;
however, the following summaries from the Colorado assessment do provide an illustration of
the nature and consequences of potential accidents.
A Maximum Incinerator Trial Burn Credible Accident scenario, primarily based on the
overpressurization of the Fluidized Bed Incinerator system, was evaluated.
4-6
-------
The CDH report lists the following assumptions for this accident evaluation:
1 hour fueled fire release and 1 hour exposure to the plume; Pasquill Stability Factor
F (least dispersion)
low average wind speed of 3 meters/second (6.7 mph); 0 meter effective stack height
(low immediate dispersion)
- X/Q from "Workbook of Atmospheric Dispersion Estimates, 1969" (DHEW) for 1.2
miles, .0000833 seconds/cubic meter
- both radioactive materials are in both forms (liquid and solid) of mixed waste
no radioactive materials are retained in the ash
- overpressure route uses three HEPA stages (release fraction = 0.005 x 0.002 x
0.002 = 0.000 000 002)
- total 1 hour inventory is released over 1 hour and the exposure is for 1 hour for dose
calculation
there is no retention or plateout in the incinerator or ventilation equipment
a 70-year dose accumulation period for all organs after the time of an assumed
"acute" exposure
Class Y materials (cleared from the lung over a period greater than 1 year
a high breathing rate of 1.2 cubic meters per hour (28.8 cubic meters per day or 1.2
liters per minute)
The resulting 70-year committed dose equivalents for the impacted organs were in the range of
1 x 1O"9 rem or smaller. The overall individual lifetime risk for radiation-caused disease
resulting from this accident scenario was conservatively calculated to be one chance in 1.09 x
109. The CDH reported that with adjustments for conservatism, this risk would fall to one
chance in 1.53 x 1017.
The CDH evaluated an "incredible" Incinerator Trial Burn Accident scenario as one in which
the entire filtering system is non-functional (destroyed). The assumptions used to calculate the
4-7
-------
70-year organ dose commitments were stated to be basically the same as those noted above,
except that no credit was taken for any filtering. The doses calculated for a 1-hour feed rate
accident was in the range of 1.8 rem or smaller for this scenario. The overall individual lifetime
risk for radiation-caused disease from this scenario was conservatively calculated to be one
chance in 2.17 x 103. Adjusted for conservatism, this number was also said to fall to 1.53 x
10".
4.1.3 Duke Power Company
Duke Power Company analyzed four potential worst case accidents in its initial submittal to the
NRC for approval to operate its low-level waste incinerator (DUK85). Duke noted that the
choice of these accidents was made after the radiological consequences of a spectrum of potential
failure events were analyzed. Subsystems and components which might contain radioactive
materials in significant quantities were identified and separated for analysis purposes as follows:
- Contaminated oil storage and feed systems.
- Wet solids storage and feed system.
- Dry active waste storage and feed system.
- Fluid bed process vessels.
- Bed material storage and transfer hoppers.
- Scrubber preconcentrator and scrub liquor recirculation circuit.
- Product Storage Hopper.
- Process Filter/Adsorber Assembly.
These components were analyzed for accident consequences on the basis of presence of activity
alone. Duke states that attempts were made to postulate mechanisms by which releases could
originate, but that the main factor in choosing worst case accidents to be analyzed in detail was
the radiological consequence potential, independent of the likelihood of occurrence. Table 4-1
lists the activity releases (in Ci) assumed for these worst case accidents.
4-8
-------
Table 4-1. Activity Releases - Worst Case Accidents (Ci) Duke
Power Company Incinerator00
Carbon Adsorber Product Hopper
Nuclide Fire Rupture
w Source: DUK85
Exponential notation, 3.7(+l) means 3.7xlO+
Scrub Circuit Trash
Failure Fire
Total 0.9
H-3 0
C-14
Mn-54
Fe-55
Ni-59
Co-58
Co-60
Ni-63
Nb-94
Sr-90
Tc-99m
Tc-99
Mo-99
1-129 l.l(-3)
1-131 9.0(+0)
1-133 2.5(-2)
1-134 1.0(-3)
Cs-134
Cs-135
Cs-137 -
3.7(+l)w 1.4
4.0(-3)
7.2(-l)
8.4(-4)
1.0(+1) -
1.6(+0)
2.6(-l)
2.7(-5)
7.8(-3)
4.0(-2) -
3.4(-5)
4.4(-2)
1.1 (-4) 1.4(-6)
7.5(+0) 1.7(-1)
2.5(-2) 3.0(-3)
1.00-3) 8.5(-4)
5.9(+0)
3.4(-5)
2.2M,
2.4(-3)
8.8(-5)
\ s
4.8(-2)
5.7(-5)
9.6(-2)
\ y
1 Q ( £\
1 8(-4)
•• •
7.3(-7)
2.2(-6)
_
.
1.7(-2)
7.'5(-7)
2.5(-2)
4-9
-------
The four accidents selected for further analysis are as follows:
(1) The Process Gas Filter Assembly was analyzed because of the long term collection
of particulate activity on the HEPA filters and iodine on the carbon adsorber.
(2) The rupture of the Product Storage Hopper was analyzed due to the large amount of
high specific activity product ash collected within the hopper.
(3) The Scrubber Preconcentrator scrub liquor circuit failure was analyzed due to the
buildup of radioactive iodine which may recirculate in the scrub circuit.
(4) A fire involving the flammable contaminated trash was also analyzed since significant
volumes of these contaminated wastes may accumulate in storage areas prior to
incineration.
The following paragraphs excerpted from the Duke submittal to the NRC briefly describe each
postulated accident, how it would be detected, and its projected radiological consequences.
Process Gas Carbon Adsorber Release - This postulated accident involves the release of
iodine activity collected on the process gas carbon adsorber. A fire of undetermined
origin involving the process gas carbon adsorber is the postulated release mechanism.
High temperatures in the carbon bed would be detected by the operator who could initiate
the fire protection system as necessary. The loss of differential pressure across the
filter/adsorber assembly would also alert the operator to the accident.
It was conservatively assumed that all iodine activity input to the Volume Reduction
Subsystem is collected on the carbon adsorber and that the adsorber was in service for
6 months prior to the event. Credit for iodine decay was taken and a 95 percentile
4-10
-------
accident X/Q of 2.2X104 s/m3 was used in the dose analysis. The resulting whole-body
dose offsite for this event was calculated to be 1.9 mrem. The maximum organ dose was
found to be 1020 mrem to the thyroid of an individual breathing air (a maximum
individual breathing rate of 3.47 x 1O3 m3/s assumed in all accident inhalation doses
calculated) at the site boundary during the event.
Product Hopper Rupture - The rupture of a loaded Product Hopper would result in the
release of dry product ash to the surrounding cubicle. Ventilation systems serving the
cubicle could transport this ash to the outside environment; resulting in offsite exposure.
A Product Hopper rupture could result from natural phenomena, such as an earthquake,
or an overpressure transient from an undetermined source within the system.
The postulated causes (i.e., explosion or earthquake) of a Product Hopper rupture would
be readily detected by the operator at the onset of any such event; resulting in immediate
Volume Reduction System shutdown. In any case, where a rupture occurred unnoticed,
the operator would be alerted by high radioactivity concentrations in the HVAC exhaust
flow, hopper pressure change, and area monitors.
It was conservatively assumed.that 100 percent of the product ash contained in a fully
loaded hopper escapes unfiltered via the cubicle ventilation system. Worst case product
ash nuclide concentrations were calculated based on calcined concentrates with an
assumed volume reduction factor of 11. The resulting particulate plume was assumed
to be transported undepleted to the site boundary. The resulting maximum whole-body
dose offsite was calculated to be 85 mrem. The maximum organ dose was determined
to be 860 mrem to the thyroid of an individual breathing air at the site boundary during
the event.
Scrub Liquor Circuit Failure - The postulated failure of the preconcentrator scrub liquor
circuit would result in the spillage of concentrated liquid containing iodine. The concern
4-11
-------
here will be the evolution of gaseous radioactive iodines which could be transported
offsite in air. Any liquid released from the scrub circuit will be contained within the
facility and should not be available for transport in ground or surface waters offsite.
The release of the scrub inventory could result from a rupture of either the Scrubber
Preconcentrator vessel or recirculation piping.
The loss of a significant quantity of scrub liquor would result in the lowering of the scrub
liquor level in the Scrubber Preconcentrator sump. This would be noticed by the
operator. If no operator action is taken or the sump inventory is lost rapidly, the process
would automatically shutdown due to loss of fluid flow to the venturi.
It was assumed that all the scrub solution in the Scrubber Preconcentrator sump and
recirculation piping is spilled. Iodine recirculation and decay within the dryer/off-gas
loop is analyzed assuming an iodine DF of 2 for the dryer/cyclone. Maximum activity
releases are calculated for each isotope. The postulated release assumes 100 percent of
the calculated maximum buildup activity is available for transport offsite. The resulting
maximum whole-body dose offsite was calculated to be 0.04 mrem. The maximum
organ dose was determined to be 20 mrem to the thyroid of the individual breathing at
the site boundary during the event.
A groundwater transport analysis was also analyzed for this postulated worst case liquid
release event. The saprolite soil characteristic of the Oconee site is an effective barrier
to the migration of radionuclides. The movement of radionuclides released in this
postulated worst case event would be so extremely slow that concentrations resulting at
the nearest potable intake would be well below 10 CFR 20, Appendix B, Table II,
Column 2 maximum permissible concentration values.
4-12
-------
Trash Fire - A fire involving contaminated trash being stored prior to incineration would
result in offsite exposure from activity transported along with other combustion products
through the air. A fire could result from accidental causes.
Facility smoke detectors would ensure prompt detection of any fire in the storage areas.
The visible smoke resulting from a fire would provide a secondary means for detection
of this postulated accident.
It was conservatively assumed that as much as 80 cubic meters of contaminated trash
activity is released and transported offsite due to the fire. The resulting maximum
whole-body dose was calculated to be 0.3 mrem. The maximum organ dose was
determined to be 5.7 mrem to the bone of an individual breathing air at the site boundary
during the fire.
For comparison, the maximum total body (child) and critical organ (infant thyroid) doses for
airborne effluents from normal operations were calculated at 1.5 x 10'3 mrem/yr and 1.8 x 10'1
mrem/yr, respectively.
4-13
-------
Chapter 4 References
BER88 Bergman, W., "Review of Some Health and Safety Aspects of the
Planned for the LLNL Decontamination and Waste Treatment Facility (DWTF),
Safety Science Group, Special Projects Division, Hazards Control Department,
Lawrence Livermore National Laboratory, December 23, 1988.
COL87 Colorado Department of Health, Rocky Flats Plant Trial Burn Health.Risk
Assessment, by Letter of Thomas P. Looby, Assistant Director, Office of HeaWi
and Environmental Protection, to Dr. Jim Ruttenbur, Center for Disease Control,
June 30, 1987.
DUK85 Duke Power Company Transmittal, Request for Approval to Operate the Oconee
Nuclear Station Radioactive Waste Volume Reduction Incinerator, by Letter ol
Hal B Tucker, Vice President, Nuclear Production, to Harold R. Denton,
Director, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory
Commission, June 10, 1985.
SEG88 Scientific Ecology Group Radioactive Waste Incinerator NESHAPS Permit
Application, Radioactive Material License Amendment Application, Air Pollution
Control Permit Application, May 19, 1988.
4-14
-------
5. Comparison of Incineration with Other Volume Reduction Technologies
A number of technologies and techniques are used to reduce the volume and radionuclide content
of solid waste. These techniques and technologies are often grouped into end-point, source, and
administrative control categories. End-point controls generally refer to technologies that reduce
the volume of solid waste after the waste has been accumulated. Incineration and compaction
are good examples of end-point techniques. Source controls emphasize reducing the volume of
waste at the point of generation. For example, segregating and decontamination/recycling of
wastes are source control techniques. Administrative controls are specific suggestions to
improve waste management operations and general housekeeping. Neat, organized, and well-
planned facilities and operations generate less waste. Advanced planning can reduce the amount
of unnecessary materials that enter radioactive areas and that become contaminated.
End-point controls include sorting, shredding, compaction, supercompaction, incineration, and
storage for decay.
Administrative and source control techniques include maximizing compactable drum weights,
landfill disposal of Below Regulatory Concern wastes, limiting access to radiation control areas,
decontamination and reuse of materials, and use of strippable coatings.
This chapter briefly reviews volume reduction factor (VRFs) associated with end-point control
technologies.
End-point volume reduction techniques are primarily applied to general trash, often referred to
as dry active waste (DAW) and consisting of a variety of materials that become contaminated
through normal operations. End-point volume reduction is best viewed as part of a process, not
the simple application of a technology. Figure 5-1 presents the overall flow of an example
process.
5-1
-------
Class A
Dry
Active
Waste
Non-radioactive
Waste
Shred
Sort
Combustible/
Compactible
Non-combustible/
Non-compactible
Compact
Incinerate
Immobilization
Solidification
Size Reduction
and
Decontamination
Non-radioactive
Waste
Radioactive
Waste
Storage/Burial
Figure 5-1. Volume Reduction Logical Process
5-2
-------
5.1 SORTING
As radioactive trash is generated, it usually receives some form of pretreatment, generally
consisting of sorting the material, such as separating combustible from noncombustible material,
prior to incineration or separating compactable from noncompactable material prior to
compaction. Hand sorting is the most direct method of segregating wastes into constituents that
are amenable to treatment by a particular technology, or into radioactive and nonradioactive
components.
Pneumatic sorting by an air or inert gas stream can also separate lower density combustible
materials, such as paper, plastic, and rags, from higher density noncombustible material such
as glass and metal. Manual sorting for radioactivity consists of using a sorting table where bags
with low radiation levels are segregated. Radiation readings used for this initial screening have
been reported as about 1 mrem/h for typical nuclear reactor facilities (NRC 81a). The contents
of these bags are opened, and the individual items are scanned and segregated. Automated trash
monitors that are more sensitive and reliable for segregating radioactive from nonradioactive
waste also are available (SHR 86; SNE 88). DAW volume deductions of 31 percent through
the use of a trash sorting table have been reported (SNE 88).
5.2 SHREDDING
Combustible and compactable materials are sometimes shredded to produce small pieces.
Shredding by itself yields some volume reduction because of the greater packaging efficiencies.
Shredding is also used to achieve improved performance of compactors and as a necessary
pretreatment for certain kinds of incinerators.
5.3 COMPACTION
Typical trash compactors, which are widely used throughout the nuclear industry, consist of a
mechanical or hydraulic ram that applies a compressive force of 430 to 2,100 psi and uses a
5-3
-------
standard 55-gallon drum as the compaction vessel. Standard compactors can potentially achieve
volume reduction factors up to 4 depending on the void volume and the resiliency of the trash.
However, the average reported volume reduction factor is 2. A shredder mated with a 1,270-psi
compactor has been developed that achieves a 50-percent greater volume reduction than a
compactor alone (NRG 81).
5.4 SUPERCOMPACTION
Supercompactors, which apply a force of about 8,000 psi, can achieve a 7-fold or greater
volume reduction factor for uncompacted dry active waste. If the waste has already been
compacted, supercompaction can achieve an additional 2to 4-fold volume reduction.
5.5 STORAGE FOR DECAY
Many radionuclides used by hospitals, universities, research facilities, and in some industrial
applications have relatively short half-lives that make it feasible to store radioactive waste for
decay. Typically, short-lived radionuclides that are stored for 10 half-lives can be considered
nonradioactive and disposed of as such. The passing of 10 half-lives reduces the radionuclide
content of the waste by a factor of 210 (or about a 1,000-fold reduction in radioactivity). It is
important to recognize, however, that a l,OOO-fold reduction in the radioactivity of waste does
not guarantee that the waste is suitable for disposal.
5.6 COMBUSTION
Most dry active waste and other forms of organic waste can be reduced in volume through
oxidation processes including incineration, pyrolysis, acid digestion, and molten salt combustion.
Incineration involves the burning of combustible materials in air or in an oxygen-rich
atmosphere. Pyrolysis is volatilization in an oxygen-deficient atmosphere that gasifies part of
the waste material. Acid digestion involves oxidation of materials by nitric acid in a
5-4
-------
concentrated sulfuric acid and nitric acid media. Molten salt combustion involves air oxidation
of combustible materials in a molten salt environment.
Table 5-1 summarizes volume reduction factors of the different types of technologies.
5-5
-------
Table 5-1. Volume reduction factors of selected technologies
Technology
Sorting
Drum Compactor
Box Compactor
Shredder/Compactor
Shredder/High-Pressure
Typical Use
Low-Level Waste
Low-Level Waste
Low-Level Waste
Low-Level Waste
Low-Level Waste
Volume
Reduction Factor
3
2
2.2
3.3
5.5
Compactor
Supercompactor
Compactor/Supercompactor
Storage for Decay
Pathological
Incinerator
Agitated
Hearth Incinerator
Controlled Air
Incinerator
Cyclone Drum
Incinerator
Rotary Kiln
Incinerator
Pyrolysis
Acid Digestion
Molten Salt
Combustion
Fluidized Bed
(Calciner)
Combustion
Low-Level Waste
Low-Level Waste
Short Half-life Waste
Institutional Trash,
Biowaste, Organic Liquids
Transuranic (TRU) trash
TRU, Low-Level Waste
Compacted TRU trash
Municipal Solid Waste,
Industrial Solid, Liquid,
and Gaseous Waste
TRU Waste
TRU Waste
Municipal Waste
and Chemical Wastes
Aqueous Waste, Shredded
Waste, Wet Solids
7.0
11.0
Potentially Very Large
Trash 20
Glass 4
Plastic > 100
Fluids > 100
Biowaste 15
Trash 40
Trash
Trash
40
43
Trash
23
Resins 18
Filter
Sludge 5
Evaporator
Bottoms 8
Trash 80
Prepared from References NRC 81 and NRC 8 la.
Denotes that the information was not provided in NRC 8 la.
5-6
-------
Chapter 5 References
NRC81 Nuclear Regulatory Commission; Data Base for Radioactive Waste Management
Waste Source Options Report. NUREG/CR-1759, November 1981.
NRCSla Nuclear Regulatory Commission; Volume Reduction Techniques in Low Level
Radioactive Waste Management. NUREG/CR-2206, September 1981.
SHR86
SNE88
Shriner, D.G. et al.; A Regional Approach to Determine Waste Segregation/Volume
Reduction Program. In "Waste Management'86". March 1986.
Snead, P.B. "Volume Reduction of Dry Active Waste by Use of a Waste Sorting
Table at the Brunswick Nuclear Power Plant" in Proceedings of the Tenth Annual
DOE Low-Level Waste Management Conference, CONF880839. December 1988.
5-7
-------
-------
6. Summary
6.1 REPORT OBJECTIVE
This report, consisting of Volume I - Technology, and Volume II - Risks of Radiation Exposure,
provides basic information on the technology and radiological risk associated with incineration
of radioactive and mixed wastes. The report is in response to a request from the State of New
Mexico to the US EPA Control Technology Center for basic information on incineration of
radioactive and mixed wastes. The approach to filling the request was to obtain information
from incinerator operators and describe the waste streams, off-gas emission control technology,
emissions monitoring principles and technology, emissions, and associated radiological risks.
It was recognized that the experience history of radioactive and mixed waste incineration
research, test, and evaluation is not as extensive as for hazardous waste incineration. As the
information gathering progressed, it also became apparent that there is a general absence of
operational data acquired in a consistent, methodical fashion that will allow direct correlations
between incinerated waste characteristics and stack radionuclide emissions. The causes for this
lack of usable data are related to waste management practice or incinerator/exhaust stack design.
6.2 INCINERATION
Incineration of combustible waste is a proven volume reduction technology. Comparisons with
several volume reduction methods are summarized below:
Compacting
Sorting
Shredding/Compacting
Supercompacting
Compacting/Supercompacting
Acid Digesting
Incinerating (Controlled Air)
Storing for Decay
Reduction Factor
2
3
3
7
11
23
40
Very Large
6-1
-------
A generic incineration flowsheet is shown in Figure 6-1. Some components, for example, "Feed
Preparation," "Feed Metering and Injection," and "Combustion," are essentially independent of
the waste contaminants; therefore, hazardous waste incineration experience with these
components is directly applicable to radioactive/mixed waste incineration. Hazardous waste
incineration "Ash Removal System," "Ash Disposal," "Offgas Cleanup System," "Residue
Treatment System," "Residue Disposal," and "Stack" experience is useful but less applicable.
Actual radioactive and mixed waste incineration data are required in order to fully describe the
effects of these components on radioactive effluents. Some pertinent characteristics of the three
incinerator types most commonly used or proposed for use with radioactive mixed wastes are
summarized below:
Rotary Kiln
Advantages
Advantages
Wide variety of liquids and solids
Accepts drums and bulk containers
High turbulence and air exposure
Can use wet gas scrubbing system
Residence time controlled by rotation
Simplified waste preparation
Temperatures to 2500eF
Disadvantages
High capital costs
Refractory damage
Possible incomplete combustion
High particulalo loading
Low thermal efficiency
Seal maintenance problems
Paniculate; in off-gas
Fluidized Bed
Solids, liquids, and gases
Accepts feed fluctuations
Relatively low acid gas formation
Lower cost emission control
Low maintenance costs
Enhanced combustion efficiency
Relatively low maintenance costs
Difficult to remove bed residuals
Bed preparation and maintenance
Relatively high operating costs
Eutectic formation
Difficult to feed irregular bulk waste
Select feed to avoid bed degradation
Controlled Air
Wide variety of solids, sludges
Long residence times
Low entrainment of ash
Complete combustion (multi-hearth)
Small fluctuations in offgas stream
Can use several fuels
High fuel efficiency
High maintenance costs
Refractory and hearth failure
Difficult to feed bulk wastes
Lower operating temperature
Slow temperature response
Difficult to control supplementary
fuel firing
6-2
-------
Waste Generation Activities
Waste Characterization
Radiological
Physical
Chemical
Non-
suitable
Wastes
Conditioning! Paniculate
1 Removal
t Gas
! Removal
Residue Treatment
System
Disposal
• Packaging
• Solidification
1 Characterization
1 Shipment
Laboratory Analysis
• Specific radionuclide
• Total Alpha
• Total Beta
• etc.
Figure 6-1. Generic Incineration Flowsheet
6-3
-------
The incinerators listed below provide the operating history of large volume radioactive/mixed
waste incineration in the U.S.
Los Alamos National Laboratory
Oak Ridge National Laboratory
Savannah River Site
Idaho National Engineering Lab
Rocky Flats Plant
Brookhaven National Laboratory
Scientific Ecology Group
Advanced Nuclear Fuels
DSSI
Duke Power Company
Commonwealth Edison Company
operable - awaiting EIS
operable - in test
shutdown for modification (B-G)
operating (WERF)
shutdown for modification
operable
operating
operating
permitting stage - operational 1991
lay-up (Oconee)
lay-up (Byron, Braidwood)
6.3 RELEVANT ISSUES
Several relevant issues regarding the incineration of radioactive and mixed waste are summarized
below. The reader is urged to refer to the respective sections of this report for more details.
A brief description of the major concerns are included for each issue.
6.3.1 Waste Acceptance Criteria
• The formulation of waste acceptance criteria is a necessary component in
establishing a quality control program designed to limit radioactive emissions and
offsite exposures.
• It should be recognized that DOE is in the process of revising its waste acceptance
criteria for low-level, TRU, and mixed wastes. Such activities have in part been
motivated by DOE's Environmental Restoration Plan, operational needs, and stricter
DOE Order guidelines. Accordingly, data characterizing past operational practices
may not always represent current or even future impacts.
6-4
-------
In establishing acceptance criteria, the radiological characterization of the waste
must address such considerations as:
List acceptable and nonacceptable radionuclides and establish a maximum
allowed concentration and quantity for each acceptable radionuclide.
Acceptability is dependent on the licensing conditions (i.e., DOE Orders), the
capability of the incinerator system to remove radionuclides from the offgas, the
limits of detection of the stack radionuclide monitoring system, and the offsite
release scenario.
Address the differences between volatile and nonvolatile radionuclides. The
behavior of radionuclides through the incineration process differs for readily
volatilized species such as iodine and nonvolatiles (refractories) such as
plutonium. Very volatile radionuclides, such as carbon and tritium, will not be
trapped by offgas systems and will escape in the stack effluent.
Detailed characterization of the waste is necessary to ensure that contaminant
concentrations do not exceed limits. Consider the halflife, decay, and initial
source quantity of each radionuclide. Waste may contain long-lived
radionuclides such as plutonium-239 and strontium-90 and short-lived
radionuclides such as iodine-131. For short-lived radionuclides, storage for
radioactive decay prior to incineration may be desirable since it may reduce
radioactivity to insignificant amounts.
Nuclear criticality is generally not a major concern, but should be addressed,
depending upon the presence of radionuclides such as plutonium and uranium.
Accumulation of such radionuclides in larger amounts in ashes and incinerator
components should be evaluated.
Acceptance criteria must also address the nonradiological characteristics of the
waste.
6-5
-------
Waste forms include liquids and solids with widely varying chemical/physical
properties, some of which may adversely affect incinerator components because
of their corrosive properties.
Low-level waste includes laboratory equipment and supplies, decontamination
debris, and miscellaneous solids and sludges.
Mixed waste may contain scintillation fluids, solvents, degreasers, lead, spent
filters, and soil.
Incinerators require consistent feed rate and content. Physical properties of the
waste, including Btu content and waste form, must be monitored to ensure
stable incinerator operating conditions.
The included low-level, TRU, and mixed waste characterization is based on
several compilations of data gathered by DOE over the past 4 years. The actual
distributions of waste volumes and properties may change because of DOE's
current activities associated with the Environmental Restoration Program.
Accordingly, the characterization and data summaries provide only a snapshot
description of low-level, TRU, and mixed waste generation, treatment, and
disposal activities at the given DOE facilities.
6.3.2 Incinerator Operations
Incinerators function best under strictly controlled, predictable, steady-state
conditions. Analysis and control of feed material to prevent fluctuating conditions
in the quantity, physical, and chemical waste characteristics are critical aspects of
operations.
6-6
-------
• Most problems encountered are associated with operational reliability and
maintenance. Problems typically include: frequent replacement of off-gas system
filters, corrosion of components, plugging of heat exchangers, incomplete
incineration, accumulation of residual ashes in systems and components not designed
for ash removal, personnel exposure, contamination control, fires in filter systems,
humidity control, and HEPA filter clogging.
• Incineration results in higher concentrations of radioactivity and higher radiation
levels in ash, when compared to the feed material. The majority of ash is collected
in the ash bin, however, small amounts are retained in other sections of the
incinerator system, creating potential removal and handling problems. Ash removal
and handling must be performed under radiologically controlled conditions. Some
of the major concerns associated with ash handling and disposal are occupational
radiation exposure and exposure to the public during transportation to disposal sites.
The TCLP toxicity test may result in ash designation as mixed or hazardous waste.
• System designs that include the merging of incinerator stack gas into a common
plenum with other effluent sources may preclude any meaningful interpretation of
effluent results. Such features make it difficult to resolve radionuclide emissions
from the incinerator. , ,
• Desirable incinerator operating characteristics for the destruction of hazardous
materials may be counter productive in minimizing some types of emissions. For
example, large residence times, normally required for the destruction of organic
compounds, may result in the greater formation of metal oxide fumes. Some
radionuclides, which volatilize at higher temperatures, may coalesce as particulates
at cooler temperatures with higher specific activity than the waste itself.
• Radioactive/mixed waste incinerators can achieve reliability, availability, and
maintainability factors similar to that experienced by hazardous waste incinerators.
6-7
-------
Batch mode or periodic operation and HEPA filter replacement or failures are
factors that adversely affect the achievement of such goals.
• Potential accident scenarios include fires and explosions, emission control systems
failures, transportation mishaps, and loss of essential utilities. Identification of
expected operational events and application of prevention/mitigation measures must
be based on specific design characteristics and operating practices.
6.3.3 Stack Monitoring
• The exhaust stream must be sampled representatively, i.e., isokinetically. The
sampling train design must include sample probe, sample collector or monitor,
flowrate meter, sampling pump, and electronic controls, such as audio/visual alarms
and shut-off systems, if needed.
• Analysis can be performed on a real-time basis by a dedicated monitoring system
with required measurement sensitivity, or conducted periodically by pulling a
sample and performing the analysis in a laboratory. Real-time system operation,
calibration, and maintenance must conform to QA/QC procedures for such systems.
Laboratory sample analysis must also be performed under radiological quality
assurance and control procedures.
• Monitoring systems using gross counting methods can provide information only on
composite activities; i.e., the sum total of the radioactivity retained on the collection
media integrated over the sampling duration period. Systems that use spectrometers
(alpha or gamma) have the capability to identify each radionuclide as a function of
time.
• Real-time radionuclide monitoring is inherently difficult. Some radionuclides,
including tritium and C-14, cannot be monitored in real-time. Areas of concern
6-8
-------
include radionuclide plateout, selection of proper sample collection media for
particulates and gases, radiation detector sensitivity, transient nature of releases,
detector response characteristics, proper equipment maintenance, and corrections for
background radioactivity.
• Off-the-shelf incinerator stack real-time monitors are not commercially available.
Several vendors and manufacturers have installed off-theshelf real-time monitors
originally designed for nuclear facilities. Many of such commercial systems are
readily adaptable to incinerator applications.
• Most of the relevant operating experience resides with DOE. Since most systems
are designed as one-of-a-kind, the potential range of application and technology
transfer are limited. DOE emissions data (required by NESHAPS) consist generally
of annual release quantities in curies, and do not correlate emissions versus waste
processing activities. NESHAPS does not require this type of reporting format
since NESHAPS is only concerned with offsite releases and public exposures.
6.3.4 Radiological Risk Assessment . • . .
• In conducting a risk assessment analysis, each step in the waste management process
(in this case incineration) must be identified and thoroughly characterized. This
characterization must typically consider waste forms and generation practices,
incinerator and facility parameters, and environmental factors or site features.
Every step of the process, from waste receipt to ash disposal and stack effluent
release, must then be analyzed for assessing the potential risks to workers and the
public, as well as environmental impacts.
• Radiological impact is waste stream specific and is based on expected waste volume,
radionuclide distributions, and waste forms for a given incinerator design and
operating practices.
6-9
-------
• A simple method with which to assess the radiological impacts associated with waste
management is given in Volume II of this report. The method allows one to devise
assess emissions, occupational exposures, and offsite doses and risks based on
generic or default radionuclide waste concentrations. This method is presented only
for illustrative purposes and is not intended to be used to conduct a formal risk
assessment analysis.
6.3.5 Airborne Radionuclide Emissions
• A review of past operating practices indicates that radionuclide emissions are
generally well below DOE standards and guidelines.
• Since all measurements are made at the point of release, radionuclide concentrations
at downwind receptor locations would be still lower than those observed at the
stack.
• DOE incinerator emissions are typically identical to their commercial counterparts,
with the exception of plutonium, americium, and uranium.
• Radionuclide emissions can be generally classified into two categories; short-lived
and long-lived. Short-lived radionuclides typically include H-3, C-14, P-32, S-35,
Cr-51, Mn-54, Fe-55, Co-57, Tc-99m, 1-125,1-131, etc. Long-lived radionuclides
include Tc-99, Cs-137, Sr90, Am-241, Pu-238, Pu-239, Pu-240, U-233, U-234, U-
238, etc.
• In general, yearly emissions of long-lived radionuclides are on the order of
10 microcuries or less. Short-lived radionuclides are, however, released, at times,
at higher activity levels.
6-10
-------
A comparison between radioactivity contained in waste feed and stack emissions
reveals that overall incinerator decontamination factors range from 1O+3 to 10+u
depending upon the type of offgas treatment system. This comparison includes all
radionuclides for which data were available except for H-3, C-14, and radioiodines.
A review of DOE and commercial incineration practices indicates that low-level
waste is incinerated in varying frequencies and volumes, and involve different waste
streams or forms, e.g., liquids, solids, etc. The data indicate that incineration
schedules typically reflect Operational needs rather than the imposition of regulatory
constraints or limits.
6-11
-------
-------
APPENDIX 1
NRC INCINERATION GUIDELINES FOR MATERIAL LICENSEES
These guidelines apply to noncommercial waste disposal, that is, incineration of a licensee's own
waste. NRC may request additional information regarding proposed commercial incinerators
as appropriate to assess adequately the potential impact on public health and safety and the
environment.
Specific NRC approval is not needed in order to incinerate certain exempted categories of
radioactive waste. For example, 10 CFR Section 20.306 provides that tritium and carbon-14
in low concentrations in liquid scintillation media and animal tissue (less than or equal to 0.05
microcuries of tritium or carbon-14 per gram of liquid scintillation medium or per gram of
animal tissue averaged over the weight of the entire animal) may be disposed of without regard
to radioactivity. This exemption does not relieve the applicant from complying with other local
requirements for the disposal of such waste.
The following information must be provided when applying to the NRC for a license to
incinerate waste requiring specific NRC approval.
1. The characteristics of the incinerator and the site must be submitted. This includes the
height of the stack, rated air flow, distance from incinerator to nearest air intake duct of
adjacent building, and location and distance to nearest unrestricted areas, residence,
school, hospital, etc.
2. The specific isotopes and the maximum amount of each isotope to be incinerated per burn
must be stated. For the combination of isotopes listed, calculations must be submitted
to demonstrate that the following conditions will be met:
A 1-1
-------
a. The gaseous effluent from the incinerator stack will not exceed the limits
specified for air in Appendix B, Table II, 10 CFR Part 20 when averaged over
a 24-hour period.
b. In order to be in compliance with the ALARA philosophy stated in 10 CPR
Section 20.1(c), the gaseous effluent from the incinerator stack should be a
fraction (less than 10 percent) of the limits specified for air in 10 CFR 20,
Appendix B, Table II, when averaged over a period of one year.
If more than one isotope is involved, the calculations must follow the "sum of ratios"
method in the note at the end of 10 CFR Part 20, Appendix B..
The method to be used to determine the concentration of radionuclides released, both as
airborne effluents, and as any liquid effluents from scrubbers, condensers, or associated
systems. , . : • . . • ,
The maximum number of burns to be performed in any one week and the maximum
number of burns per year must be stated. ,
The method for estimating the concentration of radioactive material remaining in the ash
residue must be described. The most conservative assumption must be used unless
scientific evidence to the contrary is presented.
The procedures for collection, handling, and disposal of the ash residue, including
radiation safety precautions to be observed, must be described.
The procedures to be followed to minimize exposure to personnel during all phases of
the operation, including instructions given to personnel handling the combustibles and the
ash, must be described.
A 1-2
-------
7.
a.
b.
Any State or local permits which are required to operate an incinerator must be
identified. Evidence that such permits have been obtained must be submitted.
State and local government agencies should be notified early of plans to incinerate
radioactive waste, because they often must respond to inquiries from local citizens
and organizations. It is preferable that the applicant make such notifications and
obtain comments since the applicant is closer to the community. Indication that
such notifications have been made can be done by including copies of letters to
State and local government agencies and their comments with the application. If
the applicant does not notify State and local governments, the NRC will do so
directly.
A 1-3
-------
-------
APPENDIX 2
NUCLEAR REGULATORY COMMISSION OUTLINE FOR SAFETY RELATED TOPICS
DESIGN AND OPERATION OF LOW-LEVEL RADIOACTIVE WASTE INCINERATOR
I. PRINCIPAL DESIGN CRITERIA
a. Purpose of Incinerator Program
Incinerator feed
Incinerator products and byproducts
Incinerator functions
b. Structural and Mechanical Safety
c. Safety Protection Systems
Confinement barriers and systems
Off-gas treatment and ventilation
Controls and instrumentation
Nuclear criticality safety
Radiation protection
Fire and explosion
Feed and product handling and storage
Decommissioning
II. FACILITY DESIGN
a. Summary Description
Location and facility layout
Principal features
b. Incinerator Building
Structural specifications
Building layout
Incinerator description
c. Support Systems
Support requirements
Support systems descriptions
d. Service and Utility Systems
Building ventilation
Incinerator fuel
Utilities, electrical, steam, water, etc.
Safety communications and alarms
Fire protection
Maintenance
III. PROCESS SYSTEMS
a. Process Description
Narrative
Flow diagrams and sheets
b. Process Chemistry and Physical and
Chemical Properties
c. Mechanical Process Systems
d. Waste receiving, storage, and handling,
waste feeding; Product handling,
packaging, and storage
e. Chemical Process Systems
Incineration
- trash,
- resins,
- liquids,
- others
f. Process Support Systems
Instrumentation and control
Maintenance and repair
g. Waste Feed, Product, and Byproduct
Analyses
IV. PROCESS CONFINEMENT AND
MANAGEMENT
a. Ventilation and Off-gas Treatment
A 2-1
-------
Waste feed ventilation
Incinerator ventilation
b. Off-gas Treatment
Equipment and system description
Operating characteristics
Operating procedures
c. Product Handling Ventilation
d. Product Handling, Packaging, and
Storage
Equipment and system description
Characteristics, concentrations, and
volumes
Packaging
Storage
e. Effluent Sampling and Monitoring
f. Airborne
g. Liquid
V. RADIATION PROTECTION
a. Radiation Sources
b. Radiation Protection Design Features
Facility design
Shielding
Ventilation
Area radiation monitoring
Airborne radioactivity monitoring
VI. ALARA Program
a. Design considerations
b. Operational considerations
A 2-2
-------
APPENDIX 3
EXCERPTS FROM ILLINOIS REGULATIONS
Section 340.1060 Concentration of Radioactivity in Effluents to Unrestricted Areas
a) A licensee or registrant shall not possess, use, or transfer licensed material so as to
release to an unrestricted area radioactive material in concentrations which exceed the
limits specified in Appendix A, Table II, of this Part, except as authorized pursuant to
Sections 340.3020 or 340.1060(b). For purposes of Section 340.1060, concentrations
may be averaged over a period of not greater than 1 year.
b) An application for a license or amendment may include proposed limits higher than
those specified in Section 340.1060(a). The Department will approve the proposed
limits if the applicant demonstrates:
1) that the applicant has made a reasonable effort to minimize the radioactivity
contained in effluents to unrestricted areas; and
2) that it is not likely that radioactive material discharged in the effluent would
result in the exposure of an individual to concentrations of radioactive material
in air or water exceeding the limits specified in Appendix A, Table II, of this
Part.
c) An application for higher limits pursuant to Section 340.1060(b) shall include
information demonstrating that the applicant has made a reasonable effort to minimize
the radioactivity discharged in effluents to unrestricted areas, and shall include, as
pertinent:
1) information as to flow rates, total volume of effluent, peak concentrations of
each radionuclide in the effluent, and concentration of each radionuclide in the
effluent averaged over a period of 1 year at the point where the effluent leaves
a stack, tube, pipe, or similar conduit;
2) a description of the properties of the effluents, including:
A) chemical composition,
B) physical characteristics, including suspended solids content in liquid
effluents, and nature of gas or aerosol for air effluents,
C) the hydrogen ion concentrations (Ph) of liquid effluents; and,
A 3-1
-------
D) the size range of particulates in effluents released into air;
3) a description of the anticipated human occupancy in the unrestricted area
where the highest concentration of radioactive material from the effluent is
expected, and in the case of a river or stream, a description of water uses
downstream from the point of release of the effluent;
4) information as to the highest concentration of each radionuclide in an
unrestricted area, including anticipated concentrations averaged over a period
of 1 year:
A) in air at any point of human occupancy, or
B) in water at points of use downstream from the point of release of the
effluent;
5) the background concentration of radionuclides in the receiving river or stream
prior to the release of liquid effluent;
6) a description of the environmental monitoring equipment, including sensitivity
of the system, and procedures and calculations to determine concentrations of
radionuclides in the unrestricted area and possible reconcentrations of
radionuclides; and
7) a description of the waste treatment facilities and procedures used to reduce
the concentration of radionuclides in effluents prior to their release.
d) For the purposes of Section 340.1060, the concentration limits in Appendix A,
Table II, of this Part shall apply at the boundary of the restricted area. The
concentration of radioactive material discharged through a stack, pipe, or similar
conduit may be determined with respect to the point where the material leaves the
conduit. If the conduit discharges within the restricted area, the concentration at the
boundary may be determined by applying appropriate factors for dilution, dispersion,
or decay between the point of discharge and the boundary.
e) In addition to limiting concentrations in effluent streams, the Department may limit
quantities of radioactive material released in air or water during a specified period of
time if it appears that the daily intake of radioactive material from air, water, or food
by a suitable sample of an exposed population group, averaged over a period not
exceeding 1 year, would otherwise exceed the daily intake resulting from continuous
exposure to air or water containing one-third (1/3) the concentration of radioactive
material specified in Appendix A, Table II, of this Part.
A 3-2
-------
f) The provisions of Section 340.1060 do not apply to disposal of radioactive material
into sanitary sewage systems, which is governed by Section 340.3030.
g) In addition to the other requirements of this Part, licensees or registrants engaged in
uranium fuel cycle operations shall also comply with the provisions of 40 CFR 190,
"Environmental Radiation Protection Standard for Nuclear Power Operations," revised
as of July 1, 1984, exclusive of subsequent amendments or editions.
(Source: Amended at 10 111. Reg. 17538, effective September 25, 1986)
Section 340.3020 Method of Obtaining Approval of Proposed Disposal Procedures
a) Any person may apply to the Department for approval of proposed procedures to
dispose of radioactive material in a manner not otherwise authorized in this part.
Each application shall include a description of the radioactive material, including the
quantities and kinds of radioactive material and levels of radioactivity involved, and
the proposed manner and conditions of disposal. The application, where appropriate,
should also include an analysis and evaluation of pertinent information as to the nature
of the environment, including topographical, geological, meteorological, and
hydrological characteristics; usage of ground and surface waters in the general area;
the nature and location of other potentially affected facilities; and procedures to be
observed to minimize the risk of unexpected or hazardous exposures.
b) The Department will not approve any application for a license to receive radioactive
material from other persons for disposal on land not owned by a State or the Federal
Government.
(Source: Amended to 10 111. Reg. 17538, effective September 25, 11986)
Section 340.3050 Disposal by Incineration
No licensee or registrant shall incinerate radioactive material for the purpose of disposal or
preparation for disposal except as specifically approved by the Department pursuant to
Sections 340.1060 and 340.3020.
(Source: Amended at 10 111. Reg. 17538, effective September 25, 1986)
A 3-3
-------
Note: Following are selected pages from Section 340, Appendix A
§340.APR.A
SECTION 340. APPENDIX A
CONCENTRATION IN AIR AND WATER ABOVE NATURA1 BACKGROUND
Element
(atomic
number)
Actinium (89)
Americium (95)
Antimony (51)
Argon (18)
Arsenic (33)
Astatine (85)
Isotope1
Ac-227 S
I
Ac-228 S
I
Am-241 S
I
Am-242m S
I
Am-242 S
I
Am-243 S
I
Am-244 S
I
Sb-122 S
I
Sb-124 S
I
Sb-125 S
I
Ar-37 Sub2
Ar-41 Sub
As-73 S
I
As-74 S
I
As-76 S
I
As-77 S
I
At-211 S
I
Table I
Column 1 Column 2
Air Water
(uCi/mn (uCi/ml)
2X10-12
sxio"!1
** *' * Q
8X10-°
2X10"b
6X10-12
1x10-1°
6X10 10
3X10-1°
4X10-°
5X10-°
6X10 10
1x10-1°
4X10'°
2X10-3
2X10-7
1X10l7
2X10-8
5X10-7
3X10-8
6X10'3.
2X10'6
2X10-5
4X10l7
ixio-7
ixio-;
1X10-7
5X10-7
4X1Q-7
7X10-3
3X10-b
6X10-5
9X10-3
3X10-3
3X10-3
8X10'4,
1X10-5
3X1Q-3
4X10-3
4X10-3
mo:4,
ixio-}
1X10'1
8X10-^
7x10-5
7X10-5
3X10-3
3X10-3
lAlU -
2X10-3
2X1Q-J
6X10-5
2X10-3
2X10-3
2X10'3
Table I
I
Column 1 , Column 2
Air Water
(uCi/ml) (uCi/ml)
9X10-J3
3X10-3
6X10-10
2X10-13
4X10-}2
2X1Q-J3
2X10-3
2X10-}3
4X10'^
1X10-7
8X10"7
6X10-3
5X10-3
5X10-3
7X10-1°
2X10-°
9X10-10
lxlo"s
4X10"b
7X10-8
4X10-3
4X10-3
3X10-3
2X10-°
1X10-8
2X10-1°
!X10"y
«}•:!
9X10'^
9X10-=
3X10'^
4X10-°
9X10'=
4X10-^
3X10'=
5X10-3
3X10-f
3X10'=
2X10"=
2X10"J
5X10-1
5X10-4
5X10"=
5X10'=
2X10-5
8X10-=
8X10-=
7X10-5
340-39
January, 1987
A 3-4
-------
§340.APR.A
C 1 Aff*t**M-fc>
t lement
(atomic
number)
Californium (98)
Carbon (6)
Cerium (58)
Cesium (55)
Chlorine (17)
» i 1
Isotope1
Cf-249 S
I
Cf-250 S
I
Cf-251 S
I
Cf-252 S
I
Cf-253 S
I
Cf-254 S
I
(Co2) Sub2
Ce-141 S
I
Ce-143 S
I
Ce-144 S
I
Cs-131 S
I
Cs-134m S
I
Cs-134 S
I
Cs-135 S
I
Cs-136 S
I
Cs-137 S
I
Cl-36 S
I
Cl-38 S
I
Table ]
Column 1
Air
fuCi/ml)
2X10-}2
1x10-}°
5X10-}2
1X10-}°
2X10-}2
1x10-}°
6X10-}2
3X10-}*
8X10-}°
8X10-}°
5X10-}2
5X10-12
4X10'f
5X10"b
4X10"7
2X1Q-;
3X10-7
2X10
ixio-f
6X10-9
ixio-f
3X10"°
4X10'f
£ V 1 rt ™O
0/k Xu
4X10-8
IXIO"8
5X10"
9X10"?
4X10-;
2X10-7
6X10"f
1X10"8
4X10-7
2X10-°
3X10"°
2X10-6
r
Column 2
Water
(uCi/ml)
1X10-4
4X10-4
7X10-4
1X10-4
8X10-4
2X1Q-4
2X10-4
4X10-3
4X10'°
4X10'6
2X10-2
3X10-3
3X10-3
1X10-3
1X10-3
3X10-4
3X10-4
7X10'2
3X10-2
2X10-J
3X10'2
3X10-4
1X10-3
3X10-3
7X10-3
2X10-3
2X10-3
4X1Q-;
1X10-3
2X10-3
2X10-3
1X10-2
IXIO'2
Table I
Column 1
Air
(uCi/mlV
5X10-}4
3X10- 2
2X10-}3
3X10- j2
3X10- }2
2X10-J3
ixio-}2
3X10"11
11
3X10"l3
2X10-13
1X10-7
1 Yin~°
XA XU
5X1Q-9
9X10-9
7X10-9
3X10-10
2X10-10
4X10-7
1X10-7
1X10-°
2X10-;
1X10-9
4X10-J°
2X10'°
3X10-9
6X10-9
2X10"9
5X10-10
1X10"?.
8X1Q-J0
9X10-f
7X10'8
I
Column 2
Water
4X10-6
2X10-f
ixio-f
3X10-f
4X10"6
3X10-f
7X10-f
7X10-°
1X10-4
1X10-7
IXIO'7
8X10-4
9X10"5
9X10"5
4X10"f
4X10"5
1X1Q-5
IX ID'5
2X10"3
9X10*4
6X10-3
1X10*3
4X10"5
1X10-4
2X10"4
6X10-|
4X10-5
8X10"^
6X10-5
4X10-4
4X10-4
340-41
January, 1987
A 3-5
-------
§340.APP.A
—
Element
(atomic
number)
Gold (79)
Hafnium (72)
Holmlum (67)
Hydrogen (1)
Indium (49)
Iodine (53)
Isotope1
Au-195 S
I
Au-196 S
I
Au-198 S
I
Au-199 S
I
Hf-181 S
I
Ho-166 S
I
H-3 S
I
Sub2
In-113m S
I
In-114m S
I
In-115m S
I
In-115 S
I
1-125 S
I
1-126 S
I
1-129 S
I
1-131 S
I
1-132 S
I
1-133 S
I
1-134 S
I
1-135 S
I
Table
Column J
A1r
fuCI/ml]
8X10-6
6X10'°
6X10-7
3X10-;
2X10"'
1X10'°
8X10-'
4X10*3
2X10-7
2X10-7
SXlO'f
5X10"°
o\/i rt** J
2X10
8X10-?
7X10'°
1X10-7
2X10"°
2X10'°
2X10*°
2X10-7
3X10*8
5X10-9
8X10*9
3X10*7
2X10*5
7X10"°
9X10"5
3X10-7
2X10";
9X10"'
» »»»» Q
3X10-°
2X10"'
5X10*'
3X10'°
1X10-7
4X1Q-'
I
L Column 2
Water
i (uCi/ml)
4X10-2
6X10-3
5X10-3
4X10-3
2X10"J
IXIO-*
5X10-;*
4X10-3
2X10-3
2X10-3
9X10'4
9X10'4
ixio-}
IXIO'1
4X10-2
4X10**
5X10*5
5X10*4
1X10-2
3X10-3
6X10-3
5X10-=
3X10*3
6X10-3
6X10-5
2X10-3
2X10-3
5X10*3
2X10*4
2X10"2
7X10-4
Table II
Column 1 (
A1r
fuCi/ml) I
3X10-7
4X10-8
2X10-°
8X10-9
4X10-°
3X10"°
3X10-5
7X10-5
6X10-y
2X10-7
2X10*7
/I V 1 rt— 3
3X10-7
2X10"'
4X10 -y
7X10-J0
8X10-°
6X10-°
9X10-5
8X10'11
6X10"y
9X10-J1
2X10-J1
2X10-5Q
3X10-9
3X10 in
4X10- J°
7X10-5
6X10%
1X10-7
1X10-5
ixio-8
:olumn 2
Water
fuCi/ml)
IXIO'3
2x10-;
2X10-1
lxl°Is
2X10-4
2X10'4
7X10-5
3XlO-f
3X10'=
3X10-3
2X10-5
2X10-=
4X10-4
4xio':
9X10-=
9X10"=
2X10-7
2X10-;
3X10-'
9X10-=
6X10-8
2X10-4
3X10-'
6X10-=
8X10-°
4X10-5
4X10-6
7X10-=
340-44
January, 1987
A 3-6
-------
§340.APR.A
Element
(atomic
number)
Molybdenum (42)
Neodymium (60)
Neptunium (93)
Nickel (28)
Niobium (41)
)smium (76)
'alladium (46)
Isotope*
Mo-99 S
I
Nd-144 S
I
Nd-147 S
I
Nd-149 S
I
Np-237 S
I
Np-239 S
I
Ni-59 S
I
Ni-63 S
I
Ni-65 S
I
Nb-93m S
I
Nb-95 S
I
Nb-97 S
I
Os-185 S
I
Os-191m S
I
Os-191 S
I
Os-193 S
I
Pd-103 S
I
Pd-109 S
I
Table I
Column 1 Column 2
Air Water
(uCi/ml) (uCi/nfn
7X10-7
2X10'7
8x10-11
3X10-1°
4X10-;
2X10'7
2X10-°
ixio-°
4X1Q-J2
!X10-±°
8X10-;
7X10-7
5X10-7
8X10-7
6X10-?
3X10-;
9X10-;
5X10-7
1X10-7
2X10-;
5X10-7
mo'7
6X10'°
5X10-°
5X10-7
5X10-?
2X10
9X1Q-6,
4X10-7
4X10";
3X10-7
IXlO'f
7X10'7
6X1Q-;
4X10'7
5XKT3
IXIO-3
'2X10-3
2X10-3
2X10-3
8X10-3
8X10-3
9X10*5
9X10"4
4X10
4X10"3
6X10-3
6X10-2
8X10
2X10*2
4X10"3
3X10-3
IXIO-2
IXIO'2
3X10~3
3X10-3
3X10-2
3X10-2
2X10-3
2X10-3
7X10-2
7X10-2
5X10-3
5X10-3
2X10-3
2X10*3
1X10-2
8X10"
3X10-3.
2X10-3
Table
Column 1
Air
(uCi/ml)
3X10'8
7X10-9
3X10-12
1X10-1!
1X10"
8X10-|
6X10-°
5X10-8
1X10-J3
4X10-12
3X10-°
2X1Q-8
2X10'8
3X10'°
2X10-^
IXIO-8
3X10'8
o
2X10-8
4X10-9
5X10-9
2X10'°
3X10-9
2X10-;
2X10'7
2X10'8
2X10'9
6X10-;
3X10-;
4X10'8
IXlO'f
IXlO'f
9X10'9
5X10-8
3X10-°
2X10-f
IX 10'8
II
Column 2
Water
(uCi/ml)
,2X10-4
4XKT5
7X10'f
8X10-5
6X10"5
6X10"5
3X10"4
3X10'4
3xlo-6
3X10-5
ixio-4
2X10'4
2X10-3
C
3X10-5
7X10'4
ixio-4
4X10-4
4X10-4
ixio-4
IXIO'4
9X10"4
9X10"4
7X10-5
7X10-f
3X10-3
2X10-3
2X10";
2X10-J
6X10-5
5X10'5
3X10-4
3X10-4
9X10-5
7X10-5
340-46
January, 1987
A 3-7
-------
§340.APR.A
Element
(atomic
number)
Phosphorus (15)
Platinum (78)
Plutonium (94)
Polonium (84)
Potassium (19)
Praseodymium (59)
Promethium (61)
Isotope1
P-32 S
I
Pt-191 S
I
Pt-193m S
I
Pt-193 S
I
Pt-197m S
I
Pt-197 S
I
Pu-238 S
I
Pu-239 S
I
Pu-240 S
I
Pu-241 S
I
Pu-242 S
I
Pu-243 S
I
Pu-244 S
I
Po-210 S
I
K-42 S
I
Pr-142 S
I
Pr-143 S
I
Pm-147 S
I
Pm-149 S
I
Table
Column 1
Air
7X10-8
8X10"b
6X1Q-7.
7X10-°
5X10-°
3X1Q-7
6X10-°
5X10'°
8X10-;
6X10'7
2X10" 12
3X1Q-JJ
2X10- }2
4X10" JJ
2XlQ-|f
4X10-"
9X10-J1
4X10-°2
4X10"11
2X10-°
2X10-°,
2X10- }Z
3X10-11
5X10-j°
2X10- 10
2X1Q-?
1X10'7
2X10'7
3XKT7
2X10-7
6X10-8
1X10'7
3X10-7
2X10''
I
Column 2
Water
fud/ml)
5X1Q-4
4X1Q-3
3X10-3
3X10-2
3X10-2
3X10-2
5X10-2
3X10-2
3X10-2
4X10-^
3X10"J
8X10-4
1X10-5
8X10*5
1X10-5
8X1Q-;
7X10-J
4X10-2
ixio-J
9X1Q-^
1X10-2
1X10-2
1X10-5
3X10'4
2X10J
6X10"4
9X10-5
9X1Q-Z
1X10'^
1X1Q--3
6XKT3.
6X10-^
1X10"^
Table II
Column 1 Column 2
Air Water
(uC1/mn (uCi/ml)
2X10-9
3X1Q-9
3X10-8
2X10'°
2X1Q-;
2X10-7
4X10-°
2X1Q-7
2X10-7
3X10-°
2X10'S
7X10-}4
6X10Il2
6X10-J5
1X10-J2
3X10-J2
1X10-9
6X10-J2
1X1Q~¥
6X10-°
8X10"°4
1X10'12
2X10Il2
7X10-8
7X10-9
5X10-9
6X10-9
2X10-9
3X10Is
8X10"9
2X10'5
IXIO'5
1X10-5
1X10'^
1X10 *
9x10-5
2X10-3
1X10"^
9x10";
1x10-5
1X10'4
5X10'^
3X10'=
5X10"^
3X10'=
5X10-°
3X10'=
2X10-5
IXIO'J
5X10-°
** W 1 l*"> ™ J
3X10 =
3x10 :
3X10'4
mo-5
7X10"7
3X10"=
2X10'5
3X10-5
3X10-J
5X10'=
5X10'5
2X10-J
2X10"J
4X10'=
4X10'=
340-47
January, 1987
A 3-8
-------
§340.APR.A
Element Isotope*
(atomic
number)
Sr-90 S
I
Sr-91 S
I
Sr-92 S
I
Sulfur (16) S-35 S
I
Tantalum (73) Ta-182 S
I
Technetium (43) Tc-96m S
I
Tc-96 S
I
Tc-97m S
I
Tc-97 S
I
Tc-99m S
I
Tc-99 S
I
Fellurium j(52) Te-125m S
I
Te-127m S
I
Te-127 S
I
Te-129m S
I
Te-129 S
I
Te-131m S
I
Te-132 S
I
erbium (65) Tb-160 S
I
Table I
Column 1 Column 2
A1r Water
(uCi/ml) (uCi/ml)
IXIO-9
5X10-9
4X10-;
3X10-;
4X10-;
3X10"7
3X10-7
3X10-7
4X10-8
2X10'8
8X10-5
3X10"!
6X10-;
2X10-7
2X10-°
2X10-7
1X10-5
3X10-7
4X10-5
1X10
2X10-f
6X10'8
4X10-7
1X10-7
4X10-f
2X10-°
9X10-7
8X10"8
3X10-?
5X10-°
M W 1 rt*"O
ttX 1 IJ
4X10-7
2X10-;
2X10*;
IXIO-7
1X10-7
3X1Q-8
340-50
A 3-9
1X10-5
1X10"
2X10-3
2X10-3
2X10-3
2X10-3
8X10-3
1X10-3
IXIO-3
4X10*}
3X10- \
3X10-3
1X10
1X10"2
5X10-3
5X10-2
2X10-f
2X10'1.
8X10-2
1X10-2
5X10-3
5X10*3
3X10-3
2X10-3
2X10-3
8X10-3
5X10-3
1X10-3
6X10
2X10-2
2X10-2
2X10-3
1X10-3
9X10*7
6X10-4
1X10-3
ixio-J
Table II
Column 1
A1r
(uC1/mn
3X10-}*
2X10"
2X10-8
9X10-9
2X10-8
IXIO-8
9X10-9
9X10-9
1X10-9
7X10-*°
3X10'f
ixio-°
2X10-8
8X10"
8X10-8
5X10-9
4X10-7
ixio-|
5X10-7
7X10-f
2X10'9
IXIO-8
4X10-9
5X10-9
1X10-9
6X10-8
3X10-8
3X10-9
1X10-9
2X1Q-;
1X1Q-;
IXlO-f
6X10-9
7X10"9
4X10-9
3X10-9
IXIO-9
Column 2
Water
(uCi/mlV
3X10-7
4X10"5
7X10-f
5X10-5
7X10-5
6X10-5
6X10-5
3X10-4
4X10-5
4X10-5
1X10-2
1X10-2
ixio-4
4X10"4
2X10-3
8X10"4
j
6X10*3
3X10-3
3X10-4
2X10'4
2X10"4
ixio-4
6X10-5
5X10-5
3X10-4
2X10-4
3X10-5
2X10-5
8X10-4
6X10-5
4X10-5
3X10-5
2X10-5
4X10-f
4X10-5
January, 1987
-------
§340.APR.A
Element
(atomic
Uranium (92)
Vanadium (23)
Xenon (54)
Ytterbium (70)
Yttrium (39)
Isotope
U-230 S
I
U-232 S
I
U-233 S
I.
U-234 S4
I.
U-235 S4
I
U-236 S
U-238 S4
I
U-240 S
I
U-nat- A
ural S4
I
V-48 S
I
•)
Xe-131m Sub*
Xe-133 Sub
Xe-133ra Sub
Xe-135 Sub
Yb-175 S
I
Y-88 S
I
Y-90 S
j
Y-91m S
I
Y-91 S
I
Y-92 S
I
Y-93 S
I
Table I
Column 1
Air
(uCi/ml)
3X10-JO
1X10 10
3X10-J1
5X10-JO
ixio- JJ
6X10-J°
mo-jo
5X10-Jg
1x10-}°
6X10-JO
7X1Q-J1
1x10-1°
2X1Q-;
2X10'7
ixio-jo
ixio-10
2X10-J
6X10"8
2X10 g
1X10 c
1X10 j:
4X10
6X1Q-7
3X10-J
5X10-°
1X10l7
2X10-5
2X10-5
4X10-°
3X10'°
3X10-7
2X10%
1X10-'
Column 2
Water
(uCi/ml)
mjrj
8X10-}
8X10-}
9X10-}
9X10-}
9X10-}
9X10-}
8X1Q-}
8X10-4
1X10-3
1X10-*
lAiU _
1X10-3
IXIO-3
1X10-3
IXIO-3
9X10-}
8X10"4
3X1Q-3
2X10-3
3X10-^
6X10-}
6X10"4
ixio-}
IXIO'J
8X10"}
8X1Q-4
2X10-3
2X10-3
8X10'}
8X10'4
Table II
Column 1
Air
(uCi/ml)
ixio-ij
4X10-J2
3X10 1*
9X1Q-JJ
4X10-12
2X10-}1
4X1Q-J^
4X10"12
4X10-12
SXIQ-J*
5X10 _
6X10"9
5X10- J|
6X10-9
2X10"y
4X10~7
_.,1n-7
•^YlO'7
i vin-7
IxiS-S
6X10-5
2X10-y
4X10-y
3X10";
8X1Q-;
6X10-7
5X10-9
Column 2
Water
(uCi/ml)
5X10'^
3X10'^
3X10'5
3X10-5
3X10-=
3X10-5
3X10"^
3X10-5
4X10-5
4X10 ,.
3X10-5
3X10-5
3X10'b
3X10-5
ixio-}
IXIO'4
7X10"5
9X10"5
2X10-=
3X10-3
3X10-5
6X10-5
6X10-5
3X10"|
340-52
January, 1987
A 3-10
-------
§340.APP.A
n — — — • •*-
Element
(atomic
number)
Zinc (30)
Zirconium (40)
Any single radio-
• .
Isotope
Zn-65
Zn-69m
Zn-69
Zr-93
Zr-95
Zr-97
1
i*
S
I
S
I
S
I
S
I
S
I
S
I
Sub2
Table I
Column 1
Air
(ud/ml)
1X10-7
6X10-8
4X10-;
3X10
7X10'1
9XKT6
3X10-7
1X10-7
3X10-°
1X10-7
9X10-8
1X10'6
Column 2
Water
(uCi/ml)
3X10-3
5X10-|
2X10-3
2X10-3
5X10-2
5X10-2
2X10-2
2X10-2
2X10-3
2X10-3
5X10'4
5X10-4
Table I
Column 1
Air
(uCi/ml)
4X10"9
2X10-9
1X10-8
1X10*8
2X10-7
3X10-7
4X10-9
1X10-°
Q
4X10-9
4X10-9
3X10-9
3X10"8
I
Column 2
Water
(uCi/ml)
2X10'4
7X10"5
6X10"5
2X10-3
2X10-3
8X10-4
6X10-5
6X10"5
2X10-5
2X10-5
nucllde not listed
above with decay
mode other than
alpha emission or
spontaneous fission
and with radioactive
half-life less than
2 hours.
Any single radlo-
nucllde not listed
above with decay
mode other than
alpha emission or
spontaneous fission
and with radioactive
half-life greater than
2 hours.
Any single radlo-
nuclide not listed
above, which decays
by alpha emission or
spontaneous fission.
3X10
-9
9X10
-5
6X10
-13
1X10
-10
3X10
-6
4X10-7 2X10'14 3X10'8
Soluble (S); Insoluble (I),
340-53
A 3-11
January, 1987
-------
§340.APP.A
2 "Sub" means that values given are for submersion in a semi-spherical
infinite cloud of airborne material.
3 These radon concentrations are appropriate for protection from radon-222
combined with Its short-lived daughters. Alternatively, the value in Table I
may be replaced by one-third (1/3) "working level-. (A "working eve ' is
defined as any combination of short-lived radon-222 daughters, polomum-218,
I«d3l4, bismuth-214, and polonium-214, in 1 liter of air, without regard to
the degree of equilibrium, that will result in the ultimate emission of 1.3 X
10§ MeV of alpha particle energy.) The Table II value may be replaced by one
thirtieth (1/30) of a "working level". The limit on radon-222 concentrations
in restricted areas may be based on an annual average.
4 For soluble mixtures of U-238, U-234 and U-235 in air, chemical toxicity may
be the limiting factor. If the percent by weight (enrichment ) of U-235 is
less than 5, the concentration value for a 40-hour workweek, Table I, is 0.2
milUqrams uranium per cubic meter of air average. For any enrichment, the
product of the average concentration and time of exposure during a 40-hour
workweek shall not exceed 8 X 10'3 SA uC1-hr/ml, where SA is the specific
activity of the uranium inhaled. The concentration value for Table II is
0.007 milligrams uranium per cubic meter of air. The specific activity for
natural uranium is 6.77 X 10'7 curies per gram uranium. The specific activity
for other mixtures of U-238, U-235 and U-234, if not known, shall be:
SA - 3.6X10-7 curies/gram U2 (U-depleted) „
SA = (0 4 + 0 38E + Oo0034E) X 10"°, E lesser than or equal to 0.72,
where E*is the percentage by weight of U-235, expressed as percent.
NOTE:
In any case where there is a mixture in air or water of more than one
radionuclide, the limiting values for purposes of this Appendix
should be determined as follows:
1) If the identity and concentration of each radionuclide in the mixture
are known, the limiting values should be derived as follows: Deter-
mine, for each radionuclide in the mixture, the ratio between the _
quantity present in the mixture and the limit otherwise established
in Appendix "A" for the specific radionuclide when not in a mix-
ture. The sum of such ratios for all the radionuclides in the
mixture may not exceed "1" (i.e., "unity").
EXAMPLE: If radionuclides (a), (b), and (c) are present in
concentrations Ca, Cb, and C , and if the appliable maximum
permissible concentrations (MPC's are MPC , MPCu, and MPC
respectively, then the concentrations shall be limited so that
the following relationship exists:
r r C,. lesser than
Ca b 1_ or
MPC,. equal to 1
MPC,
340-54
January, 1987
A 3-12
-------
APPENDIX 4
INCINERATOR CONTROL FUNCTIONS
A 4.1
FEED SYSTEM
Waste feed system controls are designed to maximize the feed within regulatory constraints
(e.g., a maximum allowable feedrate) and operating constraints (e.g., high primary chamber
temperature, which limits feedrate when the incinerator is burning high heat value waste
materials and high gas velocity, which restricts feedrates for high moisture content and/or high
heating value waste).
In a typical feed control system, the operator inputs a setpoint to the controller. The setpoint
can be a feed rate (e.g., for a continuous feed system such as a screw feeder or liquid waste
system) or a charge weight (e.g., for a batch system such as a ram system). In a continuous
solid feed, the system would use a weigh belt or weigh hopper to sense the feedrate of solids,
compare the feedrate to the setpoint and adjust the speed of the screw feeder. In a batch system,
the charge setpoint is the primary method of controlling the feedrate. Liquid waste feedrate is
controlled by comparing the flowrate measurement with the setpoint and adjusting the position
of a control valve.
A 4,2
COMBUSTION CONTROLS
Combustion controls maintain a safe temperature in the primary and secondary combustion
chambers. This requires the interaction of control loops for temperature, supplemental fuel
flowrate, coolant flowrate, and combustion air flowrate. In an incinerator, interaction between
combustion and waste feed control loops is also possible. The combustion control systems vary
with incinerator type as follows.
A 4-1
-------
A 4.2.1
Rotary Kiln
Rotary Mln temperature is controlled by feeding the measured temperature to a controller that
compares it with the setpoint. Several scenarios are possible:
Scenario 1: The measured temperature is below the setpoint and coolant flow is
off. The control signal orders increased use of auxiliary fuel. In the lead/lag
control system, the signal increases the combustion air flow by increasing the
opening of the combustion air damper downstream of the forced draft (FD) fan.
After the air damper opens further, the fuel control valve opens proportionately.
Scenario 2: The measured temperature is above the setpoint and coolant flow is
off. The control signal causes the fuel flow to decrease by closing the fuel valve
further. When the fuel valve starts to close, the air damper closes
proportionately.
In Scenarios 1 and 2 above, the cross limiting lead/lag system ensures adequate combustion air
to maintain a stable auxiliary burner flame. Fuel and air flowrates are kept in proportion to each
other under any change in flowrate. This is the cross-limiting feature. On an increased demand
for fuel, air flow is increased followed by increased fuel flow, and on a decreased demand for
fuel, fuel flow is decreased followed by decreased air flow. This is the lead/lag feature.
In Scenarios 3 and 4 below, coolant flows are used to control the primary chamber temperatures.
In these cases, the auxiliary burner is at minimum firing. Either water or air can be used as
coolants, but water is more effective due to its higher heat capacity and the energy associated
with the latent heat of vaporization.
Scenario 3: The measured temperature is above the setpoint. The control signal
causes increased water flow by opening the water control valve further.
A 4-2
-------
Scenario 4: The measured temperature is below the setpoint, the control signal
decreases the water flow by closing the water control valve further.
Accurate temperature measurement in a rotary kiln can be difficult. The thermocouple should
be protected by a thermowell and the location should be carefully chosen to avoid inaccurate
readings. With a dry ash removal system, excessive air leakage can cause low readings. The
steam generated by a wet ash removal system can cause low readings.
The primary chamber of a rotary kiln can operate under either reducing or oxidizing conditions.
For an incinerator operating under oxidizing conditions, the use of oxygen trim control is
recommended to control excess oxygen. A solid state zirconium oxide oxygen analyzer is
preferred for this application because it can be used in situ or with a very short sampling line.
The use of an oxygen meter improves incinerator response to transients and reduces the
occurrence of carbon monoxide spikes.
The use of feedforward control when firing a liquid waste also improves the response of the
incinerator to transients. This is accomplished by measuring the feedrate of the liquid waste and
using an estimated heating value. The controller uses the feedrate measurement and the
estimated heating value to calculate an air requirement. The air requirement, converted to a
signal, acts on the air damper to the forced draft fan.
Unless the unit is of airtight construction, draft or negative pressure must be maintained
throughout any hazardous waste incineration system to prevent fugitive emissions. This is
achieved by measuring the draft at the point of highest pressure, comparing the draft to the
setpoint, and either adjusting the damper or adjusting the speed of the induced draft (ID) fan.
The location of highest pressure depends upon the type of incinerator. For a rotary kiln, the
highest pressure occurs in the primary chamber. For a controlled air incinerator, the highest
pressure may occur in either the primary chamber or secondary chamber. For a fluidized bed
incinerator, the highest pressure occurs above the air distributor, but the draft is controlled by
A 4-3
-------
the pressure in the freeboard. It is good practice to control draft with the ID fan or its dampers
and to control excess air with the forced draft (FD) fan or its dampers.
The combustion controls for the secondary combustion chamber of a rotary kiln incinerator
should be controlled in a manner similar to the primary chamber. The control, however, is less
complex. Temperature should be controlled by a cross-limited lead/lag control system.
A 4.2.2
Controlled Air Incinerator
Temperatures of the primary combustion chamber and the secondary combustion chambers are
the main control variables in the controlled air incinerator. The temperature in the primary
chamber is controlled by varying air flow. If the measured temperature is higher than the
setpoint, air flow is decreased by closing the damper that controls air flow to the primary
chamber. This reduces the rate of combustion. If the measured temperature is lower than the
setpoint, the air flow is increased by opening the damper.
The temperature in the secondary chamber is controlled by varying air flow to the chamber in
a manner opposite to the primary chamber. If the measured temperature is higher than the
setpoint, air flow is increased by opening the damper that controls air flow to the secondary
chamber. If the measured temperature is lower than the setpoint, the air flow is decreased by
closing the damper.
A 4.2.3
Fluidized Bed Incinerator
Temperature, excess air, and limestone injection rates are important control variables for
fluidized bed incinerators. The temperature of the fluidized bed incinerator responds slowly to
transient conditions due to the high heat holding capacity of the bed. Control of the temperature
can be accomplished by adding supplemental fuel, injecting water, and controlling excess air.
A minimum air flow must be maintained to ensure fiuidization. Control of excess air can be
A 4-4
-------
accomplished by oxygen trim control using an oxygen analyzer. Acid gas removal is
accomplished by controlling the feedrate of limestone injection.
A 4.3
AIR POLLUTION CONTROL SYSTEM
The quench system can bring the flue gas temperature to the adiabatic saturation temperature of
water, which is relatively constant, or to a controlled saturation temperature. The type of
system is dependent upon the type of air pollution control equipment used downstream of the
quench system.
Systems that reach the adiabatic saturation temperature do not require temperature control. Total
dissolved solids (TDS), pH of the quench water, and the level of drained water in the collection
sump may have to be regulated. TDS is controlled by measuring the electrical conductivity of
the water in the collection sump, comparing the value to a setpoint, and controlling the rate of
blowdown to maintain the setpoint. The pH of the quench water is maintained by measuring the
pH in the collection sump with a glass electrode, comparing the pH to the setpoint, and adjusting
a control valve or the speed of a metering pump to inject the proper quantity of neutralizing
agent. Level control an be obtained by measuring the level in the collection sump and by
adjusting the position of the control valve for make-up water.
Systems that do not reach the adiabatic saturation temperature require a temperature control
loop. The temperature downstream of the quench is measured and compared to the setpoint.
If the value is above the setpoint, coolant flow is increased by opening the control valve further.
A 4.4
ACID GAS REMOVAL
For rotary kilns and controlled air incinerators, acid gas removal is the main function of the
packed scrubber or the spray dryer. A venturi scrubber also removes acid gases but usually
requires a packed scrubber downstream to complete the acid gas removal.
A 4-5
-------
A 4.4.1
Packed Bed Scrubber
Scrubber liquid to gas ratio, PH, and temperature are important control variables for packed
scrubbers. The liquid to gas ratio can be optimized by calculating the ratio of the flue gas and
liquid flowrates, by comparing the ratio to the setpoint and by adjusting the liquid flowrate
control valve. Alternatively, the liquid flow can be maintained at an adequate flowrate that
provides a sufficient liquid to gas ratio throughout the operating range of the incinerator. The
PH of the scrubber liquid should be controlled by measuring the PH of the liquid exiting the
scrubber, comparing the value to the setpoint and adjusting the rate of caustic addition through
a control valve. Usually, temperature is controlled to adequately protect the particulate removal
device.
A 4.4.1
Sorav Dryer
Temperature, slurry concentration, and liquid/gas ratio are important control variables for spray
dryers. The inlet temperature of a spray dryer ranges from 400'F.to 600°F and the outlet
temperature ranges from 250°F to 300°F. Control of temperature and liquid/gas ratio is
discussed above.
A 4.5
PARTICULATE REMOVAL
The main particulate removal devices are venturi scrubbers, fabric filters (baghouses), and wet
electrostatic precipitators (WESPs). High temperature ceramic filters, sintered metal filters, and
electrostatic precipitators have also been used for particulate removal.
A 4.5.1
Venturi Scrubber
Temperature, liquid/gas ratio, scrubber water PH, and scrubber pressure drop are important
control variables for a venturi scrubber. Control of temperature, liquid/gas ratio and scrubber
water pH have been discussed above. The scrubber pressure drop can be controlled by
A 4-6
-------
measuring the differential pressure across the venturi and adjusting the throat opening to meet
the setpoint requirements.
A 4.5.2
Fabric Filter (Baghouse')
Temperature and pressure drop are the control variables for the fabric filter. Temperature
control has been discussed above. The pressure drop across the bags is controlled by periodic
cleaning.
Compressed air is directed inside each bag at set intervals to discharge the dust that has
accumulated on the external surface of the bag. Timed flow reversals are used on independent
sections of the baghouse. A shaker mechanism physically shakes bags in a section of the
baghouse. The shaker operates in sequence with fresh air dampers that provide a reversing flow
to aid dust removal.
A 4.5.3
Temperature, water flow, and direct current (DC) voltage are the critical control variables for
a wet electrostatic precipitator. Control of temperature has been discussed above. Water flow
is usually maintained at a constant rate high enough to ensure cleaning. Voltage is maintained
by an automatic controller that maintains a sparking rate. When the peak voltage drops the
WESP must be water washed to regenerate maximum paniculate removal efficiencies.
A 4.6
FINAL PARTICULATE AND RADIOACTIVE GAS REMOVAL
The primary paniculate removal devices are followed by a condensation step and a reheat step
to provide a superheated flue gas for final paniculate and radioactive gas removal (if necessary).
The condensation and reheat steps are usually accomplished by heat exchangers. The
superheated gas is then passed through a high efficiency paniculate air (HEPA) filter for removal
of ultrafine particles and a carbon adsorption bed for removal of radioactive gases.
A 4-7
-------
Temperature and pressure drop are important variables for the HEPA filters and the carbon
adsorption beds. These are usually monitored.
A 4-8
-------
APPENDIX 5
INCINERATOR MONITORING SUBSYSTEMS
A5.1
FEED SYSTEM
Feed system monitors check the operation-of the feed preparation equipment, check the
atomization parameters for the liquid waste, and measure the feedrates of solid and liquid
wastes. The feed preparation equipment must be operating to ensure adequate size distribution
of the solid wastes sent to the incinerator. Because high liquid waste pressures may cause
overfeeding of the incinerator, and low atomizing media pressures could produce emission
problems due to inadequate atomization, waste and atomizing media pressure must be monitored.
If the liquid waste requires heating, the liquid waste temperature should also be monitored to
ensure adequate atomization. For fiuidized bed incinerators, limestone or other acid gas removal
agents must be monitored to ensure adequate acid gas removal.
A 5.2
PRIMARY COMBUSTION CHAMBER
The primary combustion chamber temperatures and pressures must be monitored. Temperature
monitoring ensures adequate waste destruction, and protects equipment. High temperature
produces agglomeration in fiuidized beds and slagging and refractory damage in rotary kilns and
controlled air incinerators. Pressure must be monitored to prevent loss of vacuum that can cause
fugitive emissions from openings in the primary chamber. Since fiuidized bed incinerators have
no secondary combustion chamber, low oxygen and high carbon monoxide concentrations must
be monitored at the chamber exit to ensure adequate waste destruction.
A 5.3
BURNER SYSTEM
The burner systems associated with both the primary and secondary chamber are monitored
separately but the monitored variables are identical. The primary purpose of the burner
A 5-1
-------
monitoring system is to prevent explosions. Burner monitoring consists of checking fuel,
combustion air, and atomizing media pressures; completion of purge; and loss of flame. Low
fuel pressure must be monitored to prevent unstable flames. High fuel pressure is monitored
to prevent extinction of flames due to blowoff and to prevent overfiring. Low combustion air
pressure and low atomizing air pressures are also monitored to prevent unstable flames. An air
purge is required to remove potential accumulations of fuel which could explode if exposed to
an ignition source. The flame is monitored to prevent an accumulation of an explosive mixture
after a flameout.
A burner trip for loss of flame and/or lack of air purge is recommended for startup of the
incinerator. However, for most of the incinerator operating time these trip functions are not
required or even recommended, as discussed below. Loss of flame should only generate an
alarm when the incinerator is operation above 1400°F. The 1400°F level is a temperature at
which it is generally agreed that accidental fuel input would be ignited by the hot incinerator
interior before a hazardous accumulation could occur. This rule does not apply to boilers which
contain cold waterwalls. A purge prior to burner light-off is unnecessary if combustion is
already occurring in the combustion chamber.
A 5.4
SECONDARY COMBUSTION CHAMBER
The secondary combustion chambers used in rotary kilns and controlled air incinerators must be
monitored for temperature, oxygen, carbon monoxide, and residence time. High temperature
must be monitored to prevent damage to the equipment. Low temperature, low oxygen
concentration, high carbon monoxide concentration, and residence time (gas velocity) are
monitored to ensure adequate waste destruction.
A 5.5
AIR POLLUTION CONTROL SYSTEM
The air pollution control system consists of a quench unit plus devices to control emissions of
gases and particulates. With the exception of the burner trip required for high temperature or
A 5-2
-------
loss of coolant flow in the quench, an out-of-limit variable produces a feed cutoff to protect
against emissions.
The quench reduces the temperature of the hot gases that exit from the combustion equipment
to levels suitable for the downstream air pollution control equipment. Temperature and coolant
fiowrates are the main variables monitored. High temperature is monitored to protect the
downstream equipment. If a baghouse or dry electrostatic precipitator is used, low temperature
is monitored to control particulate emissions because liquid interferes with the proper operation
of these devices. Coolant fiowrates are monitored to ensure adequate cooling.
The variables monitored for a venturi scrubber are pressure drop, vacuum, liquid-to-gas ratio
or liquid flowrate, and scrubber water pH. Pressure drop, pH, and liquid-to-gas ratio or liquid
flowrate, are monitored to prevent excessive particulate emissions. High vacuum is monitored
to protect the equipment.
Fabric filters or baghouses are monitored for broken bags and high pressure drops. These
variables are monitored to prevent excessive particulate emissions and to protect the baghouse.
Wet electrostatic precipitators are monitored for low DC voltage and water fiowrates. Low DC
voltage indicates inadequate field strength for adequate particulate removal. Inadequate water
fiowrates cause ineffective washing of plate surfaces.
Packed scrubbers are monitored for low scrubber water flowrate, pH of the scrubber water, and
high pressure drop. Adequate pH and scrubber water flowrate are required to achieve
satisfactory acid gas removal. High pressure drop indicates that cleaning is necessary.
HEPA filters and carbon beds are monitored for high pressure drops to determine when
changeout of the HEPA filter element or the carbon bed module is required.
A 5-3
-------
A 5.6
GENERAL MONITORING
The subsystems which affect the entire incinerator are the ID fan, instrument air supply, and
electrical power supply. Loss of vacuum, excessive vibration of the ID fan, low instrument air
pressure, or loss of electrical power result in a burner trip.
A 5.7
AIR POLLUTION MONITORS
In addition to the equipment monitors, air pollution monitors record carbon dioxide (used for
efficiency calculations on PCB incinerators), total hydrocarbons, nitrogen oxides, and sulfur
dioxide.
A 5-4
-------
APPENDIX 6
COST ELEMENTS
A 6.1 CAPITAL COSTS
Capital costs are classified as direct or indirect. Direct costs include site preparation,
equipment, materials, and labor necessary for physical construction of the plant. Indirect costs
include engineering, permitting, regulatory costs, and financing costs.
A 6.1.1 Site Preparation Costs
These costs include planning, management, site design and development, equipment, utility
preparation, emergency and safety equipment. Also included are soil excavation, feedstock
preparation, and feed handling costs which will vary with the site.
A 6.1.2 Permitting and Regulatory Costs
These costs are associated with regulatory compliance and may include national or regional
permits. Preparation of permit applications, sampling and analysis plans, quality assurance
project plan, and trial burn reports are usually required. A trial burn may be required to prove
overall system performance. The costs of performing the trial burn as well as sampling and
analysis activities should be included.
In addition, the costs for developing operating procedures and training operators, as well as
health and safety operating manual should be considered.
A 6-1
-------
A 6.1.3 Equipment Costs
These costs include the design, engineering, materials, and equipment procurement, fabrication,
and installation of the incinerator. These direct costs include all subsystems and components,
for example, the emission control equipment.
A 6.1.4 Start-up and Fixed Costs
After the incinerator is constructed and training is completed, the unit must be started and
operated to check the mechanical and technical integrity of the equipment and controls.
A 6.2 OPERATING COSTS
Operating costs include operation, maintenance, transportation, and disposal. Operations and
maintenance include the direct cost of material, labor, replacement parts, consumable goods
(filters, drums, clothing), utilities, and tools.
A 6.2.1 Labor Costs
This category includes personnel such as operators and supervisors, usually ranging from 2 to
8 percent of the total annual cost. Labor costs can be reduced by increased system automation;
they are also affected by the size of the plant, its location, and operating time.
A 6.2.2 Supplies and Consumable Goods
These include filters, drums, clothing, health and safety supplies, and chemicals (such as caustic
soda solution for acid gas scrubbing). Fuel (oil, gas) costs depend on the heat value of the waste
feed.
A 6-2
-------
A 6.2.3 Utility Costs
These costs vary with the incinerator utilization. Fuel is required for the secondary combustion
chamber heating requirements. Power costs include electrical requirements for pumps, fans,
mixers, belt drives, lighting, etc. Water may be used for cooling, and in scrubber solution
makeup.
A 6.2.4 Disposal
Transportation and disposal costs depend on the type of material, the distance transported, and
the type and availability of a disposal site. In the case of radioactive waste, these costs can be
significant. Exhibit 2 is the Barnwell, South Carolina, rate schedule for disposal of low-level
radioactive waste, effective April 1, 1989.
A 6.2.5 Analytical Costs
In order to ensure that a unit it operating efficiently and meeting environmental standards, a
program for continuously analyzing waste feed, stack gas, ash, and water quality is required.
A 6.2.6 Modification. Repair, and Replacement Costs
These costs vary with system design, waste feed composition, and site characteristics. Five
percent of the installed cost is sometimes used for this category.
A 6.2.7 Indirect Operating Costs
These include taxes, insurance, administration expenses, overhead, and capital charges. For
taxes, insurance, and administration, 4 percent of the capital cost is used for some estimates.
A 6-3
-------
-------
Appendix 7
General Operations Problems and Preventive Maintenance Actions
TABLE A 7-1 Typical Feed Problems
Source of Problems
Consequence of Problem
Preventive Maintenance
Action
PVC-HC1
Rubber - SO2
Teflon - F
Batchwise feeding system
Air pollution control (APC) Proper materials selection;
system corrosion. control system design.
Can exceed chemical release APC system design
limits. modification.
Can exceed chemical release APC system design.
limits.
Transient off-gas Afterburner will reduce
composition and temperature off-gas problems; feed small
with occurrence of batches.
incomplete combustion.
A 7-1
-------
TABLE A 7-2 Typical Combustion Operating Problems
Source of Problems
Consequence of Problem
Preventive Maintenance
Action
NOX - formation at
t> 2200°F
Volatilization (metal oxides)
Incomplete combustion
Puffing
Release limit exceeded
Deposition on heat
exchanger and filters.
Accumulation of
radionuclides. Clogging.
Filter clogging. Release
limits exceeded.
Overpressure inside furnace,
possibility of outside
contamination.
Control temperature.
Scrubbing or ammonia
injection.
Subcool vapors.
Improve incineration.
Design problem. Provide
pressure relief valve to stack
or relieve overloading.
A 7-2
-------
TABLE A -7-3 General Maintenance and Troubleshooting Air Pollution Control Equipment
Equipment
Indicators
Problems
Recommended
Maintenance and
Troubleshooting
Quencher Erratic outlet temp.
Partially plugged nozzles
High variation incinerator feed
moisture
Low gas flow rate (< 30 ft/sec)
Water droplets impinging on
thermocouple
Inspect and replace plugged nozzles
Control moisture feed to incinerator
Increase gas flow rate to design
range
Relocate thermocouple, replace
defective nozzles
Consistently high outlet
temperature
• Plugged nozzles
• Lower water flow rate and high
temperature
• Excessive gas velocity (> 50 ft/sec)
Inspect and replace plugged nozzles
Calibrate water flowmeter to adjust
for evaporation loss
Reduce gas flow rate
Venturi
scrubber
Erratic pressure
differential
Plugged nozzles
Erosion
Corrosion
Adjustable throat diameter is too
wide
Inspect headers, flanges, and
nozzles
Reduce throat diameter and adjust
liquid flow rate
Inspect throat regularly for deposits
and wear
Absorption
scrubber
Surging pressure
differential (>10%)
Face velocity in excess of 12 ft/sec
Plugged tray sections
Nonuniform scrubber liquor
distribution
Leaking seals
Localized plugging of packing
Hole in the packing
Flooding
Inspect spray nozzles, water flow
rate weir boxes, and downcomers
for proper operation and seals.
Inspect packing; adjust caustic
concentration to 15-20 percent
• Decrease liquid flow rate
• Check for plugging of packing
Fabric filter
(baghouse)
Excessive pressure
differential
Excessive gas flow rate
Bag blinding (high dust loadings)
Leaking air lock or dampers
Faulty cleaning mechanism
Excessive dust accumulation in
clean side of bags
Reduce gas flowrate; check
bleed air
Inspect cleaning mechanism;
replace bags
Check proper temperature of gas to
prevent condensation
Inspect for proper removal of
collected ash from hoppers
A 7-3
-------
TABLE A 7-4 Recommended Inspection and Maintenance Frequency
Operation
Equipment/parameters Calibration
Incinerator equipment
Waste feed/fuel (2)
systems
O and CO Monitors Weekly
Gas How monitors:
• Direct gas velocity Weekly
• Indirect fan amps 6 months
Other incinerator
monitoring equipment
(flame scanners, air
blowers, etc.) —
APC
APC support systems —
APC performance
instrumentation Weekly
I&M Frequency
and Monitoring eauioment
Inspection
Daily
Daily
Continuous
Continuous
Continuous
Daily
Weekly
Daily
Daily
Service
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
Emergency systems
Alarms waste cutoffs
Weekly
Weekly
Weekly
Weekly
Weekly
—
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
Weekly
• —
Weekly
Weekly
(1) Equipment manufacturer recommendation.
(2) Equipment manufacturer recommendation or no less than monthly.
Source: Acurex 1986
Frankel 1987c
A 7-4
-------
TABLE A 7-5 Operating Parameters for HEPA Filters
Range
Comment
Temperature
Flow rate
Pressure drop
Humidity
Particulate loading
Efficiency
Corrosive gases
250°F maximum
500°F maximum
1000°F maximum
4200-160,000 fWhr
1.0" H2O
2.0" H20
0-95%
up to 4.5 Ib
99.97%
Up to several percent of NOX, HNO3,
and HF in gas stream
particle board frame and rubber
base adhesive
steel frame and silicon adhesive
steel frame and glass packing seal
clean pressure drop at rated flow
particulate loaded pressure drop
condensation should be avoided
depends on particle size, humidity,
and surface area of filter
as tested with 0.3 urn DOP aerosol
acid-resistant fibers (Nomex or
Kerler), separators, and sealants are
used
A 7-5
-------
TABLE A 7-6 Off-Gas Cleaning System Operating Problems
Source of Problem
Consequence of Problem
Preventive Maintenance Action
Humidity
Temperature below the dewpoint of
inorganic acids
High release of acid
Clogging of filter (HEPA).
Corrosion.
Clogging (condensation of acids and
tars).
H-3 (Tritium).
C-14.
Cs, Ru, Zn.
HCi, NOX, SOX) and HF
High content of HC and solid burnable Risk of fire in filter system.
particles in the offgas
Low decontamination factor (DF)
Mixing chamber
Quencher
Heat exchangers
Build-up on precoated high temperature
filters
Bag filter
Personnel exposure
Increasing of off-gas mass.
Higher water content in the off-gas
which gives higher corrosion risk.
Plugging of the tubes giving high
pressure drop and/or reduced heat
transfer coefficient.
Corrosion.
Filter life.
Secondary waste.
Risk of fire and holes.
Secondary waste or formation of HF if
incinerated.
Reheat or add heater.
Reheat if scrubber is used or keep
temperature between 175-190°F.
Remove acid gases.
Special development needed.
Same as above.
Problem not likely.
Cooling before filtration to <480°F;
HEPA filter recommended.
Scrubbing needed.
Cannot be treated as gas; must be
treated in the process itself.
Improvement of the incineration process
is needed or installation of spark
catcher.
For better DF, improve the incinerator
process.
Install easy handling systems for
maintenance and operation.
Increasing size of equipment is
necessary.
Special feeding system is needed to
control cooling rate.
Periodic cleaning is necessary.
Material and design problem.
More efficient secondary combustion.
High efficiency of filtration for particles
>3 microns.
A 7-6
-------
EXHIBIT 1
Combustible Mixed Waste volumes in storage as of April
Facility
Los Alamos National Laboratory
Lovelace Inhalation Toxicology
Mound_ Plant
Pantex
Argonne National Laboratory - East
Argonne National Laboratory - West
Brookhaven National Laboratory
Grand Junction Project Office
Idaho National Engineering Laboratory
Colonie Interim Storage Site
Fernald
Oak Ridge National Laboratory
Paducah Gaseous Diffusion Plant
Portsmouth Gaseous Diffusion Plant
Weldon Spring Remedial Action Project
Bettis Atomic Power Laboratory
Naval Reactors Facility
Hanford Site
Rocky Flats Plant
Santa Susana Field Laboratory
Lawrence Berkeley Laboratory
Savannah River Site
(a> Obtained from DOE/EM-32. 2/19/91
Combustible Cm3) &W
LLW TRU
12.5
1.1
16.3
3.6
12.5 37.5
0.6
3.3
0.1
7281.7 9622.0
2.1
5.0
12.4
10.6 1.7
9.8
37.5
0.3
0.2
106.4 95.6
112.1 97.3
2.6
3.2
Combustible Non-
combustible Mix Cm3') (°)(d)
LLW TRU
4.0
0.1 0.2
3.8 0.1
2844.7 1549.0
0.6
19.0
680.0
0.4
22.0 22.5
1.9
3967.1 3043.0
(b)
(c)
(d)
Low level waste (LLW) and transuranic waste (TRU) radioactive mixed waste matrices containing
greater than 90% combustible material
Low level waste (LLW) and transuranic waste (TRU) radioactive mixed waste matrices containing at
least 10% volume of both combustible and noncombustible materials
Does not include waste quantities subject to solvent Land Disposal Restriction rules
El-1
-------
-------
EXHIBIT 2
BARNWELL LOW-LEVEL RADIOACTIVE
WASTE MANAGEMENT FACILITY
RATE SCHEDULE
All radwaste material shall be packaged in accordance with Department of Transportation and Nuclear
Regulatory Commission Regulations in Title 49 and Title 10 of the Code of Federal Regulations, Chem-
Nuclear's Nuclear Regulatory Commission and South Carolina Radioactive Material Licenses, Chem-Nuclear's
Bamwell Site Disposal Criteria, and amendments thereto.
1. BASE DISPOSAL CHARGES:
(Not including Surcharges, Barnwell County
Business License Tax, and Cask Handling Fee)
A. Standard Waste
B. Biological Waste
C. Special Nuclear Material (SNM)
$36.87/ft3
$38.52/ft3
$36.87/ft3
plus $4.75 per Gram SNM
None: Minimum charge per shipment, excluding Surcharges and specific other charges is $800.00.
2. SURCHARGES:
A. Weight Surcharges (Crane Loads Only)
Weight of Container Surcharge Per Container
, 0 - 1,000 Ibs.
1,001 - 5,000 Ibs.
5,001 - 10,000 Ibs.
10,001 - 20,000 Ibs.
20,001 - 30,000 Ibs.
30,001 - 40,OOO Ibs.
40,001 - 50,000 Ibs.
greater than 50,000 Ibs.
No Surcharge
$ 430.00
$ 760.00
$1,070.00
$1,390.00
$2,030.00
$2,670.00
By Special Request
B. Curie Surcharges for Shielded Shipment:
Curie Content Per Shipment Surcharge Per Shipment
$ 2,650.00
$ 2,990.00
$ 3,980.00
$ 5,990.00
$ 7,320.00
$ 9,910.00
$11,870.00
$15,900.00
$19,900.00
$23,900.00
$31,800.00
By Special Request
0 -
5 -
15 -
25 -
50 -
75 -
100 -
150 -
250 -
500 -
1,000 -
5,000
5
15
25
50
75
100
150
250
500
1,000
5,000
Effective April 1, 1989
(4537g)
E2-1
-------
EXHIBIT 2 (Continued)
Bamwell Rate Schedule
Page Two
C. Curie Surcharges for Non-Shielded Shipments Containing Tritium and Carbon 14:
Curie Content Per Shipment Surcharge Per Shipment
0-100
Greater than 100
No Surcharge
By Special Request
D. Class B/C Waste Polyethylene High Integrity Container Surcharge
TvpeofHIC
(1) Large liners with maximum
dimension of 82" diameter
and 79" height
(2) Overpacks with maximum
dimension of 33" diameter
and 79" height
(3) 55-gallon drum size with
maximum dimension of 25.5"
diameter and 36" height
(4) Poly HICs which do not conform
to one of the above three
categories require prior approval.
Surcharge Per HIC
$4,700.00
$1,570.00
$400.00
Upon Request
E. Special Handling Surcharge may apply on unusually large or bulky containers. These
types of containers are acceptable upon approval of prior request.
3. OTHER CHARGES
A. Cask Handling Fee
B. Taxes and Special Funds
1. Extended Care Fund
2. South Carolina Low-Level Radioactive
Waste Disposal Tax
3. Southeast Regional Compact Fee
$1,050.00 per cask, minium
$2.80 per ft3
$6.00 per ft3
$.66 per ft3
4. A 2.4% surcharge is added to each bill to cover Barnwell County Business License
Taxes.
NOTE: ITEMS 3.B. 1, 2, AND 3 ARE INCLUDED IN ITEM 1, BASE DISPOSAL CHARGES.
Effective April 1, 1989
(4537g)
E2-2
-------
EXHIBIT 3
Half Lives of Selected Radionuclides
Nuclide
H-3
C-14
P-32
S-35
Cr-51
Mn-54
Fe-55
Fe-59
Co-60
Ni-63
Zn-65
Se-75
Sr-90
Zr-95
Nb-95
Tc-99
Mo-99
1-125
1-129
1-131
Cs-134
Cs-137
Ce-144
Pb-210
Po-210
U-234
U-235
U-238
Np-237
Pu-238
Pu-239
Pu-240
Pu-241
Am-241
Half Life
12.3y
5730 y
14.28 d
87.39 d
27.70 d
312.20 d
2.68y
44.56 d
5.27 y
100. ly
244.0 d
118.45 d
28.82 y
63.98d
34.97 d
2.12 x lO'y
66.02 h
60.25 d
1.17x 107y
8.04 d
2.06 y
30.17y
284.5 d
22.26 y
138.37 d
2.446 x 10s y
7.038 x 10s y
4.468 x 10* y
2.14x lO^y
86.4 y
2.41 x 10" y
6,580 y
14.3 y
432 y
Radiation Emitted
beta
beta
beta
beta
electron capture
electron capture
electron capture
beta
beta
beta
electron capture
electron capture
beta
beta
beta
beta
beta
electron capture
beta, gamma
beta
beta
beta
beta
beta
alpha
alpha
alpha
alpha
alpha, beta
gamma
alpha, gamma
alpha, gamma
alpha, gamma
alpha, beta
alpha, gamma
Principle Means of
Production
Fission; Li-6 (n,d)
N-14 (n,p)
P-31 (n, gamma)
S-34 (n, gamma)
Cr-50 (n, gamma)
Fe-56 (d, alpha)
Fe-54 (n, gamma)
Fe-58 (n, gamma)
Co-59 (n, gamma)
Ni-62 (n, gamma)
Zn-64 (n, gamma)
Se-74 (n, gamma)
Fission
Zr-94 (n, gamma)
Daughter Zr-95
Fission, Mo-98
(n, gamma)
Mo-98 (n, gamma)
Sb-123 (alpha, 2n);
daughter Xe-125
Fission
Fission
Cs-133 (n, gamma)
Fission
Fission
Descendant Ra-226
Daughter Bi-210
Daughter Pu-238
Natural source
Natural source
U-238(n,2n)
U-237 (beta)
Np-237 (n, gamma)
Np-238 (beta),
daughter Cm-242
U-238 (n, gamma)
U-239 (beta),
Np-239 (beta)
Multiple n-capture
Multiple n-capture
Daughter Pu-241
*U.S. GOVERNMENT PRINTING OFFICE: 1991—517-003/47010
E3-1
-------
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
EPA 520/1-91-010-1
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Radioactive and Mixed Waste Incineration Background
Information Document: Volume I - Technoloov
5. REPORT DATE
1991
PERFORMING ORGANIZATION CODE
'. AUTHOR(S)
Office of Radiation Programs and Center for Technology
Control
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Protection Agency
Office of Radiation Programs (ANR-461)
401 M St., S.W.
Washington, D.C. 20460
10. PROGRAM ELEMENT NO.
11, CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS USEPA ~
Office of Air and Radiation and Office of Research
and Development
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
This background document, consisting of Volume I - Technology and Volume II - Risks of
Radiation Exposure, provides a broad look at technology issues surrounding the inciner-
ation of radioactive and mixed wastes. It is intended to highlight major consideration
and to provide direction that would enable the reader who must deal in depth with
incineration to focus on and seek specific information on concerns appropriate to a
particular situation. It is not a comprehensive text on incinerator design, use or
regulation. The information presented in Volume I was gathered by telephone -contacts
with operators of existing incinerators, site visits, agency contacts, and literature
searches. The contents present a. distillation of material deemed to be most relevant;
it includes only a small fraction of the total amount of information collected.
Wherever possible, actual operating data have been used to illus-trate principles, how-
ever, inconsistencies in operational data acquisition have resulted in very limited
availability of data that can be used for general assessment or purposes of comparison.
Even though the existing data base on operation and resulting emissions and ash resi-
dues from radioactive waste incinerators is still quite small, it has been demonstrated
that incineration can achieve significant volume reductions for radioactive waste.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Radwaste Treatment
Radwate Incineration
.Mixed Waste Incineration
Radwaste or .Mixed Waste Reduction
Thermal Destruction
Volume Reduction
8. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS (Tills Report)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (This page I
22. PRICE
EPA Form 2220—1 (Rev. 4—77) PREVIOUS EDITION is OBSOLETE
-------
-------
-------
-------