>EPA
           United States
           Environmental Protection
           Agency
             Air And Radiation (ANR-460)
             Research And Development
             (MD-13)
EPA 520/1-91-010-1
May 1991
Radiation And
Mixed Waste Incineration
Background Information Document
Volume 1: Technology

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Radiation And
Mixed Waste Incineration

Background Information Document
Volume 1: Technology
       control  technology center
                               Printed on Recycled Paper

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                                               EPA 520/1-91-010-1
                                                        May 1991
          BACKGROUND DOCUMENT ON
RADIOACTIVE AND MIXED WASTE INCINERATION

            VOLUME I - TECHNOLOGY
              Work Assignment Manager
                  Madeleine Nawar
             Office of Radiation Programs
         U.S. Environmental Protection Agency
                 401 M Street, S.W.
               Washington, DC 20460
                  Prepared under:

               Contract No. 68-D9-0170



                   Prepared for:

              Control Technology Center
         U.S.  Environmental Protection Agency
      Research Triangle Park, North Carolina 27711

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                                  DISCLAIMER
Mention of any specific product or trade name in this report does not imply an endorsement or
guarantee on the part of the Environmental Protection Agency.

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                                       PREFACE
       This project to provide technical guidance on radioactive and  mixed waste (low-level
 radioactive contaminated  waste) incineration was funded by the Control Technology Center
 (CTC).   Work on this project was primarily directed and performed by EPA's Office of
 Radiation  Programs (ORP).  This cooperative effort was  established to provide necessary
 technical expertise and funding to compile information needed by air pollution control agencies
 considering permits for these incinerators.                        '

       The CTC was established by EPA's Office of Research and Development (ORD) and
 Office of Air Quality Planning and Standards (OAQPS) to provide technical assistance to state
 and local air pollution control agencies.  The two sponsoring organizations for the CTC are the
 Air and Energy Engineering Research Laboratory (ORD) and the Emission Standards Division
 (OAQPS).  Three  levels  of assistance  can be accessed through the  CTC.   First,  a CTC
 HOTLINE has been established  to provide telephone assistance, on  matters relating to air
 pollution control  technology.  Second, more in-depth engineering assistance can be provided
 when appropriate.  Third, the CTC can provide technical guidance  through the publication of
 technical guidance documents, development of personal computer software, and presentation of
 workshops on control technology matters.  To access CTC services,  call the CTC HOTLINE -
 (919) 541-0800 or  (FTS)  629-0800.

       Technical  Guidance projects, such as this one, focus on topics  of national or regional
 interest that are identified through contact with state and local agencies.  In this case, the State
 of New Mexico contacted the CTC and requested technical  assistance with regard to permit
 applications for mixed waste incinerators.  It became evident that incineration of radioactive and
 mixed wastes is being  considered or implemented as  a waste volume  reduction method at a
 number of facilities handling nuclear  material.  The CTC  contacted ORP  to discuss  the
possibility of a joint venture whereby CTC would provide funding and ORP  would provide
 technical expertise and project management.  This technical guidance document is the result of
 that cooperative effort.
                                          iii

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                              ACKNOWLEDGEMENT

This document was prepared for EPA's Control Technology Center (CTC), Research Triangle
Park, North Carolina, by the Office of Radiation Programs (ORP), with support from Sanford
Cohen & Associates, Inc. (SC&A), of McLean, Virginia.
ORP wishes to thank the  following individuals for their technical assistance and  review
comments on the drafts of this report: especially Bob Blaszczak (CTC Co-Chair), Jeff Telander
(OAQPS), Irma McKnight (ORP-Program Management Office),  Martin  Halper  (Director,
Analysis and Support Division [ASD], ORP), Robert Dyer (Chief Environmental  Studies &
Statistics Branch, [ESSB] ASD, ORP), Ben Hull (ESSB/ASD), Lynn Johnson (ESSB/ASD),
Hank May (EPA-Region 6, Radiation Programs), Stan Burger (EPA-Region 6, RCRA Permits
Branch), Lewis Battist (ORP-ASD), Bill Blankenship, Gale Harms and Albion Carlson (New
Mexico, Air Quality Bureau); and Stephen Cowan, Betsy Jordan and Leanne Smith (DOE-HQ,
Office of Waste Operations, Environmental Restoration and Waste Management).

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                              Table of Contents
ABSTRACT  . .		xv

1.    Overview of Radioactive and Mixed Waste Incineration Experience .  .....  1-1

      1.1    Radioactive and Mixed Waste Characteristics  . . .	 .  1-1

            1.1.1 Low-Level Radioactive Waste .....................  1-2
            1.1.2 Transuranic Waste	  1-6
            1.1.3 Mixed Waste	1-7
            1.1.4 Incinerable Waste	1-10

      1.2  Combustion Process and Radionuclide Emissions . .	 .''..1-15

            1.2.1 Radionuclide Airborne Emissions  	1-15
            1.2.2 Radiological Properties of Ashes and Residues	1-19

      1.3    Incinerator Population . .	'....'	1-24
      1.4    Operational Incinerator Emissions	 1-36

            1.4.1 DOE Incinerators	 1-36
            1.4.2 Commercial Incinerators	1-59
            1.4.3 Institutional Incinerators		1-63
            1.4.4 Studsvik Incinerator	 1-65

      1.5    Operations and Maintenance Practices and Procedures .	1-67
      1.6    Regulatory Requirements ........ 		1-68

            1.6.1 Nuclear Regulatory Commission Licensing	 1-68
            1.6.2 Resource Conservation and Recovery Act
                 (RCRA) Requirements	 1-71
            1.6.3 State Regulations	 1-72

      References	 1-75

2.     Technologies for Controlling Incinerator Processes
      and Radionuclide Emissions	 .	.2-1

      2.1  Process Control Technology	 2-1
      2.2  Process Monitoring Technology	2-2
      2.3  Emission Control Technology	2-8
                                    Vll

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                            Table of Contents (Continued)
             2.3.1 Removal of Particulates	.2-15
             2.3.2 Removal of Gases	. . , . 2-22

       2.4 Capital and Operating and Maintenance Costs	2-24
       2.5 Operations and Maintenance Concerns	 . 2-25

              2.5.1 Pretreatment	 . .2-25
              2.5.2 Feed System	2-25
              2.5.3 Combustion Chamber	2-26
              2.5.4 Air Pollution Control System	2-28

      2.6    Incinerator Effectiveness	2-31
      2.7    Incinerator Reliability	 .2-33
      References	•  • -2-35


3.    Technologies for Monitoring Incineration and Radionuclide
      Airborne Emissions . .	3-1

      3.1    Radionuclide Airborne Emissions Monitoring Technology .	3-1

             3.1.1  Stack Off-Gas Sampling Systems	3-2
             3.1.2  Real-Time Radiation Monitoring Systems  	3-14
             3.1.3  Indirect Radiation Monitoring Methods	3-16
             3.1.4  Instrumentation Detection Limits	3-18

      3.2    Radiation Process Monitoring Technology Description,
             Principle of Operation, and Applications	3-25
      3.3    Applicability of Non-Radioactive Emissions Stack
             Monitoring Methods to Radionuclides	3-26
      3.4    Monitoring Radionuclide Concentration in Incinerator Ash  ....... 3-27
      References		3-30


4.    Consideration of Incinerator Accident and Abnormal
      Operation Scenarios	4-1

      4.1    Example Analyses of Incinerator  Accident Scenarios	  4-4

             4.1.1  Scientific Ecology Group  	4-4
             4.1.2  Rocky Flats	 4-6
                                        Vlll

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                           Table of Contents (Continued)


            4.1.3  Duke Power Company	4-8

      References		 .4-14

5.     Comparison of Incineration with Other Volume Reduction
      Technologies	5-1

      5.1    Sorting	  5-3
      5.2    Shredding	5-3
      5.3    Compaction	5-3
      5.4    Supercompaction	5-4
      5.5    Storage for Decay	  5-4
      5.6    Combustion	5-4

      References	• • •  5-7

6.     Summary		6-1

      6.1    Report Objective	  6-1
      6.2    Incineration	 .  6-1
      6.3    Relevant Issues	 .  . .	6-4

              6.3.1 Waste Acceptance Criteria	  6-4
              6.3.2 Incinerator Operations	6-6
              6.3.3 Stack Monitoring	6-8
              6.3.4 Radiological Risk Assessment	6-9
              6.3.5 Airborne Radionuclide Emissions	6-10


Appendices

Appendix 1  NRC Incineration Guidelines for Material Licensees	 Al-1
Appendix 2  Nuclear Regulatory Commission Outline for Safety Related Topics
            Design and Operation of Low-Level Radioactive Waste Incinerator  . A2-1
Appendix 3  Excerpts from Illinois Regulations	 A3-1
Appendix 4  Incinerator Control Functions ..... .... . .... .... ,	A4-1
Appendix 5  Incinerator Monitoring Subsystems	 A5-1
Appendix 6  Cost Elements		A6-1
Appendix 7  General Operations Problems and Preventive Maintenance Action . . A7-1
                                       IX

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                                   List of Tables
Table Numbers
 1-1   LANL Typical Low-Level Radioactive Waste Generation and
      Disposal Reflecting Past Cumulative Practices  .		1-3

 1-2   LLW Generators That Incinerated Waste in 1984	  1-5

 1-3   Waste Form Distribution and Incineration Reported by
      Institutional Facilities  	1-6

 1-4   LANL Total Inventories of Retrievable TRU Waste Through 1987	  1-8

 1-5   Radionuclide Composition and Waste Mix of Buried and
      Retrievably Stored TRU Wastes Reflecting Past Practices
      at LANL	1-9

 1-6   Approximate Distribution and Chemical Constituent Content
      of Mixed Waste Forms	1-11

 1-7   Estimated Yearly Mixed Waste Volume and Mass Generation
      Rate by Physical Forms for LANL	1-12

 1-8   Summary Characterization of Waste Volumes, Radiological
      Properties, and Inventory at LANL .	 .  .	1-14

 1-9   Typical Distribution of Ash in Incinerator Components	1-20

 1-10  Typical Radionuclide Distribution in Incinerator Ash  .	1-22

 1-11  Status of Selected U.S. Radioactive and Mixed Waste
      Incinerators	1_33

 1-12  International Operational Large Scale Incinerators	1-35

 1-13  Rocky Flats Fluidized-Bed Incinerator Emissions	1-39

1-14  Rocky Flats Fluidized-Bed Incinerator Stack Radionuclide
      Concentrations	  	1-39

1-15  LANL TRU Controlled Air Incinerator Emissions	 1-41

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                            List of Tables (continued)
                                                                        Page
1-16  LANL TRU Controlled Air Incinerator Stack Radionuclide
      Concentrations	 .  .1-41

1-17  LANL Bldg-37 (Including CAI) Pu-239 Stack Releases  ............. .1-43

1-18  LANL Bldg-37 (Including CAI) Mixed Fission Products
      (Beta) Stack Releases	 1-44

1-19  LANL Controlled Air Incinerator Radioactive Throughputs  . . .	1-46

1-20  Oak Ridge TSCA Incinerator Emissions and Waste Feed
      Radioactivity for 1988	 1-47

1-21  Oak Ridge TSCA Incinerator Stack Radionuclide Concentrations  ........ 1-48

1-22  Brookhaven National Laboratory Low-Level Radioactive Waste
      Emissions	  .1-49

1-23  Brookhaven National Laboratory Low-Level Radioactive Waste
      Monthly Incinerator Emissions for 1987-1989	 1-50

1-24  Brookhaven National Laboratory Low-Level Radioactive Waste
      Incinerator Stack Concentrations	 .1-52

1-25  Idaho Engineering Laboratory WERF Incinerator Emissions	 1-52

1-26  Idaho Engineering Laboratory WERF Incinerator Monthly
      Emissions and Processed Waste Volumes	1-54

1-27  Idaho Engineering Laboratory WERF Incinerator Low-Level
      Radioactive Waste Radionuclide Concentrations	 1-55

1-28  Idaho Engineering Laboratory WERF Incinerator Stack
      Concentrations	. .... . ... .1-57

1-29  Idaho Engineering Laboratory WERF Incinerator Overall
      Decontamination Factor	 1-57

1-30  Savannah River Site Beta-Gamma Incinerator Emissions	1-58
                                      XI

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                               List of Tables (continued)
 1-31   Savannah River Site Beta-Gamma Incinerator Processed Waste
       Volume and Activity:  1986-1988  . .  . .	1-60

 1-32   SEG Incinerator Waste, Emissions, Ash Radionuclide
       Distribution for 1989	1-61

 1-33   SEG Incinerator Atack Wmissions  - 4th Quarter 1989	1-62

 1-34   Advanced Nuclear Fuels Solid and Liquid Waste Volumes
       and Uranium Mass	1-64

 1-35   Effluent Release Rates for Low-Level  Radioactive Waste
       Incinerators - 1984	 1-66

 1-36   Radionuclide Emissions from the Swedish Studsvik Incinerator
       Facility	1-66

2-1    Incineration System Control Functions	.2-3

2-2    Incinerator Monitoring Subsystems  	2-9

3-1    Summary of Stack Monitoring System Response	3-19

4-1    Activity Releases - Worst Case Accidents Duke Power
       Company Incinerator	4-9

5-1    Volume Reduction Factors of Selected Technologies	  5-6
                                        Xll

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                                  List of Figures
Figure
Numbers
Page
1-1   The Los Alamos Controlled Air Incinerator	1-25
1-2   The Oak Ridge Toxic Substances Control Act Incinerator	 1-26
1-3   The Rocky Flats Fluidized Bed Incinerator	1-27
1-4   The INEL Waste Experimental Reduction Facility	1-28
1-5   The Savannah River Beta-Gamma Incinerator	 1-29
1-6   The INEL PREPP Incinerator	1-30
1-7   The Scientific Ecology Group Incinerator	1-31

3-1   Typical Radioactive Airborne Emission Sampling System  .	3-4
3-2   Conceptual Diagram Showing Stack Monitor Location and
      Sampling Layout	 3-5
3-3   Typical EPA Particulate Airborne Emission Sampling System	 3-7
3-4   Typical EPA Volatile Organic Sampling System	 3-8
3-5   Typical Isokinetic Sampling Probe .	 .  .3-10

5-1   Volume Reduction Logical Process	5-2

6-1   Generic Incineration Flowsheet		.6-3

Exhibits

1     Combustible Mixed Waste Volumes
2     Barnwell Rate Schedule
3     Half-Lives of Selected Radionuclides
                                       xm

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                                      ABSTRACT

 This background document,  consisting of Volume I - Technology and Volume H - Risks of
 Radiation Exposure, was prepared for the EPA Office of Radiation Programs as part of an EPA
 Control Technology Center project  to  assist the  State  of New  Mexico Environmental
 Improvement Division/ Air  Quality Bureau.  It provides a broad look at technology issues
 surrounding the incineration of radioactive and mixed wastes.  It is intended to highlight major
 considerations 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 this report was gathered by telephone contacts with operators of existing
 incinerators,  site visits,  agency  contacts, and literature  searches.   This report presents a
 distillation of the 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 illustrate principles, however, 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 operations and resulting emissions and ash
residues from radioactive waste incinerators is still quite small, it has been demonstrated that
incineration can  achieve  significant  volume reductions for radioactive waste.  Individual
incinerator design characteristics and the specific waste stream to be processed will significantly
affect the comparison of the benefits to be gained from volume reduction versus the associated
costs and risks from emissions and ash residue.
                                          xv

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          1. Overview of Radioactive and Mixed Waste Incineration Experience

1.1 RADIOACTIVE AND MIXED WASTE CHARACTERISTICS

Providing a detailed description of the complete spectrum  of radioactive and mixed wastes
generated in the United States is beyond the scope of this project.   Therefore, this section
provides only an overview of radioactive and mixed wastes.  Most, but not all, of the data
presented focus on waste generated at the Los Alamos National Laboratory (LANL)  in support
of U.S. Department of Energy (DOE) defense and research related activities, and by facilities
included in  surveys conducted by  the Conference of Radiation Control  Program Directors
(CRCPD) and the University of Maryland.

The emphasis on LANL waste derives from the project objective to assist the State of New
Mexico. It should be noted that the quantities and types of waste generated DOE-wide can not
be inferred from LANL waste information. Further, the emphasis on LANL has no implication
relative to its contribution to the total volume of DOE waste.  DOE is currently collecting
information on the volumes of combustible waste generated  at each DOE site.  A preliminary
summary of combustible mixed waste volumes is shown in Exhibit 1. Finally, it should be noted
that, although not yet fully operational, the Toxic Substances Control Act (TSCA) Incinerator
at Oak Ridge is DOE's principal incineration activity.

For this report, waste is broadly characterized as low-level radioactive waste (LLW), transuranic
(TRU) wasteland mixed  waste.  This characterization is not intended to represent current
activities, but rather to provide perspective on the different types of chemical  and  physical
forms, radionuclide distribution, radioactivity levels, and quantities based on past aggregate
practices. The types of waste which are routinely generated do in fact vary greatly  depending
on the type of research, production, and cleanup activities that may be typically undertaken at
a given facility.  The  data reflect past practices in an aggregate form rather than on  a yearly
generation rate basis.
                                         1-1

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1.1.1 Low-Level Radioactive Waste

Low-level radioactive waste is normally acceptable for disposal in a land disposal site.  By
definition, low-level radioactive waste does not include high-level radioactive waste, spent fuel
elements or rods, transuranic waste, and uranium and thorium tailing waste. Low-level waste
may contain a number of mixed fission products, typically about 100 different radionuclides,
depending on the radiological half-life, radioactive decay, and initial amounts present. Waste
may contain long-lived  radionuclides, such as strontium-90, technetium-99,  iodine-129 and
tritium.  Short-lived nuclides such as iodine-131 may also be present.

The typical LLW volume and radionuclide distributions at LANL are shown in Table 1-1.  Dry
solids, decontamination  debris, and contaminated  equipment, in decreasing order, make up
nearly 96 percent of the total waste volume. Over 99 percent of the total activity is contained
in dry solids, decontamination debris, and in unspecified waste forms. Reported radionuclides
include primarily tritium (95.8 percent) and fission products (1.7 percent), with the balance
comprising uranium,  thorium, and alpha emitters with concentrations  of  less than 100
nanoCuries/gram.  Equivalent data for other DOE sites can be found in  "Integrated Data Base
for 1989:  Spent Fuel and Radioactive Waste Inventories, Projections, and Characteristics"
(DOE89).

In 1982 and 1984, the Conference of Radiation Control Program Directors (CRCPD) surveyed
the low-level radioactive waste disposal practices, including incineration, of nearly all radioactive
material licensees in the United States (CRC84).  Licensees were asked to report the volume and
activities of waste disposed of and incinerated in those years.  Individual survey forms were
obtained  and used in the preparation of this report.
                                         1-2

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Table 1-1.    LANL typical low-level radioactive waste generation and disposal reflecting past
             cumulative practices (a)
Physical Form
Contaminated equipment:
Decontamination debris:
Dry solids:
Solidified sludge:
Other forms or not classified:
Radionuclides
Uranium/Thorium:
Fission Products:
Tritium:
Alpha (less than 100 nCi/g):
Percent of Total
Volume Activity
14.0 0.4
22.0 30.3
60.6 50.0
3.1 0.0
0.2 19.3

- 0.02
1.7
- 95.8
- 0.4
(a)  Extracted from Tables 4.4, 4.6, and 4.7, DOE/RW-0006, Rev. 5, Nov., 1989 (DOE89).

(b)  Only principal items listed, in order of importance.
                                         1-3

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The CRCPD survey  defined  60 categories of licensees.  However,  many of these did  not
incinerate waste. For this summary, the 60 categories were aggregated into 10, as shown in
Table 1-2. The volumes, nuclides and types of waste reported as incinerated by these licensees
are also shown in Table 1-2. The average volume of waste incinerated was 1,600 cubic feet per
licensee.  Most of the volume was reported by nuclear fuel fabricators.  Five such facilities
reported incinerating  183,000 cubic feet, with one facility responsible for  130,000 cubic feet.
The activity contained in such waste was principally  from uranium radionuclides.   Facilities
classified as academic (research and education) incinerated over 21,000 cubic feet of low-level
radioactive waste in 1984. Four hospital categories  combined incinerated an estimated 33,000
(adjusted) cubic feet  of waste.   The categories  of private research  and development,  and
manufacturing each accounted for approximately 11,700 cubic feet of incinerated waste.

A survey conducted in 1979 by the University of Maryland revealed that 45 out of 142 licensed
institutional facilities routinely incinerated radioactive wastes (EGG80).  The facilities surveyed
included hospitals (16.9 percent), hospitals combined with medical schools and universities (48.6
percent), medical schools only (7.7 percent), medical schools and universities (16.9 percent),
and universities only (9.9 percent).

In the University of Maryland survey, waste forms routinely incinerated were characterized in
eight categories (see Table 1-3).  The survey breakdown indicates that essentially all facilities
incinerate animal or other forms of biological wastes.  It is not uncommon for such facilities to
incinerate two or more different waste forms; hence,  the cited values need not add up to 100
percent.  Scintillation fluids and vials typically make up less than 18 percent of the waste being
incinerated. Aqueous and organic liquid wastes were cited by 13 and 11 percent of the facilities
surveyed, respectively.
                                            1-4

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                 Table 1-2.  LLW generators that incinerated waste in 1984(a)
Volume Incinerated(ft3)
Category Average Range
Nuclear Fuel Fabricators 36,500 434-1.3 x 10s
Hospitals/Clinics/ Private Offices 300 1-4,903

Medical Research Hospitals 440 1-3,900

Academic (Research and Education) 449 1-1,198

Medical Laboratories 32 1-150
VA and Federal Hospitals 579 2-5,177

State Hospitals 142 12-579

State & Federal - Non-medical 449 8-1,008
Private R&D 345 6-2,200
Manufacturing 1,342 8-7,800
All 1,594 1-1.3 X 10s
Principal
Nuclides
U-235,
U-238
C-14, H-3, 1-
125

H-3, C-14

H-3, C-14, S-
35, P-32

1-125, H-3
H-3, C-14, S-
35

H-3, C-14

H-3, C-14
C-14, H-3, S-
35
H-3, C-14, I-
125, U-238
—
Waste Types(b)
Trash &. Solids
Trash & Solids,
Liquid Scint.,
Animal
Carcasses
Trash & Solids,
Animal
Carcasses,
Liquid Scint.
Trash & Solids,
Animal
Carcasses,
Liquid Scint.
Liquid Scint.
Trash & Solids,
Animal
Carcasses,
Liquid Scint.
Animal
Carcasses
Liquid Scint.,
Trash & Solids
Animal
Carcasses,
Liquid Scint.,
Trash & Solids
Animal
Carcasses,
Liquid Scint.

(a)   Values  are as reported and are not adjusted for the survey response rate.  Source:
     DOE/ID/12377, 1984 (CRC84).

(b)   Only principal items listed, in order of importance.
CRCPD Survey,
                                               1-5

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Table 1-3.    Waste form distribution and incineration reported by institutional facilities(a)
    Waste Forms Incinerated
Percent of Respondents That
   Incinerated This Form
    Free scintillation fluids
    Empty scintillation vials
    Full scintillation vials
    Other organic liquids
    Aqueous liquids
    Animal carcasses/other biological wastes
    Dry solid waste
    Other waste-not specified
        11.1
         4.4
        17.8
        11.1
        13.3
        95.6
        28.8
        17.8
(a)  Practices characterizing 45 out of 142 surveyed facilities.  Extracted from Appendix C,
     EGG-WM-5116, April 1980 (EGG80).
1.1.2 Transuranic Waste                                          ,..-...

The EPA standards (40 CFR Part 191) define transuranic waste (TRU) as containing more than
100 nanoCuries/gram of alpha-emitting transuranic isotopes, with half-lives greater than 20 years
(EPA89). The alpha emitting isotopes of plutonium, curium, americium, and neptunium found
in transuranic waste present a hazard because of their long radiological half-lives and potential
chemical toxicity. Most radionuclides contained in TRU waste are typically present at low
concentrations (DOE89, EPA89).  Although a few decay products have energetic gamma, beta
and neutron emissions, their most significant hazard is due to alpha radiation emissions.

In contrast to other radioactive waste, TRU waste includes liquid and solid materials with widely
varying chemical and physical properties.  Most TRU waste is classified as "contact-handled"
(CH) TRU waste, i.e., it has a surface dose rate of less than 200 milliRoentgen per hour (mR/h)
or less, and can be handled with just the shielding that is provided by the waste package itself.
A smaller volume (2.5 percent) may be contaminated with sufficient beta,  gamma, or neutron
                                          1-6

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 activity to require remote handling.  This waste is categorized as "remote-handled" (RH); i.e.,
 it has a surface dose rate of greater than 200 mR/h.

 The estimated inventories of retrievably  stored TRU waste at LANL are shown in Table 1-4.
 The total amount and activity in contact handled waste is greater than that of RH waste by nearly
 three orders of magnitude.  The bulk  of the waste  consists  of noncombustible  materials,
 combustibles, and absorbed liquids or sludges.  These waste forms are more predominant in CH
 waste and are about equally divided between stored and newly generated waste.

 The radionuclide compositions of various TRU waste buried or retrievably stored at LANL,
 sorted by DOE waste mixes, are given in Table 1-5. The waste mixes represent variations in
 waste compositions based on  the total amount of the waste volume placed in  storage and
 generated.   The DOE literature does not identify the source of waste according  to origin or
 process.  Four radionuclides make up essentially all of the waste activity. These radionuclides,
 in decreasing order, are plutonium-239, americium-241, uranium-235, and uranium-238. Mixed
 fission products  make up a small fraction of the total activity.  The remaining radionuclides
 (plutonium-238,  plutonium-240, plutonium-241, and other unspecified nuclides) make up less
 than a few percent of the total inventory. Again, equivalent data for other DOE  sites can be
 found in the report,  "Integrated  Data  Base for  1989: Spent Fuel and  Radioactive Waste
 Inventories,  Projections, and Characteristics" (DOE89).

 1.1.3 Mixed Wastes

By definition, mixed waste  contains radioactivity as well  as chemical hazardous constituents.
Such waste is in physical or chemical forms which do not readily allow, the separation of the
radioactive and nonradioactive species. Mixed waste is subject to the Atomic Energy Act (AEA)
and the Resource Conservation and Recovery Act (RCRA) and is primarily governed
                                         1-7

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      Table 1-4.  LANL total inventories of retrievable TRU waste through 1987(a)
Quantity and
Activity
Volume (m3):
TRU Mass (Kg):
Alpha Activity (Ci):
Waste Composition(%>)
Absorbed liquids
or sludge
Combustibles
Contact Handled
7,452
542
187,717
Contact Handled
Stored New
22 10
8 25
Remote Handled
11.1
0.7
63
Remote Handled Buried
Stored New
4
50 50 7
   Concrete or cemented
   sludges

   Soil, gravel, or
   asphalt

   Filters or glass
   media

   Glass, metal, or
   similar non-
   combustibles
36      15
30     48
50     50
44


30


 2



13
(a)  Extracted from Tables 3.5 and 3.7, DOE/RW-0006, Rev. 5, Nov., 1989 (DOE89).
                                        1-8

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Table 1-5.    Radionuclide composition and waste mix of buried and retrievably stored TRU
             wastes reflecting past practices at LANL(a)
Radionuclide Composition (weight percent)
Sorted By Waste Mix Designation(b)(c)
Contact Handled
Radionuclides 1234 5
U-235:
U-238:
Pu-238: 5 0.5 1.2 0.5
Pu-239: 92 21.5 98.893.0100
Pu-240:
Pu-241:
Am-241: 3 78 6.5
Mixed fission
products:
Others:
Remote Handled
78
47 47
28 28

22.7 22.7
2.1 2.1
0.2 0.2


(d) (e)

Buried
IQ

5
1
91


3.3


0.69
(a)  Extracted  from Table 3.8,  DOE/RW-0006,  Rev. 5,  Nov., 1989  (DOE89).   The
     designation of "waste mix" is used by DOE to differentiate between batches of wastes of
     varying compositions.
(b)  For radionuclides that are either > 1 percent by weight, or  > 1  percent by activity
     compared to the total.
(c)  Mixes represent major variations in waste composition based on the total of the volume in
     storage and generated.
(d)  Trace amounts by weight-percent, but comprises 85 percent of the activity.
(e)  Trace amounts by weight-percent, but comprises 95 percent of the activity.
                                          1-9

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by EPA regulations under 40 CFR Parts 260, 262-265, 268, and 270 (EPA87).  Section 6001
of RCRA explicitly subjects all Federal facilities and their activities to State and Federal
regulations under RCRA.  However, RCRA Section 1006(a) relieves facilities operating under
the authority and control of the AEA from compliance with RCRA for conditions which would
be inconsistent with the requirements of the AEA.

As with the other waste forms described earlier, the presence of organic compounds and metals
in mixed waste will vary significantly from year to year. Accordingly, the following description
is given to illustrate, not to characterize, LANL practices for a specific time period.  Table 1-6
indicates that  most of the mixed waste at LANL  consists of solidified materials, solutions,
combustibles,  and metals, representing over 90 percent of the total
waste by weight.  Mixed  waste constituents also vary over a wide range of concentrations.
Organic compounds, which may include halogenated solvents, polymers, liquid scintillation
cocktails, lathe coolants,  degreasers,  and oils, vary from a few to several hundred thousand
ppm. Metals  are reported at still higher concentrations, up to one million ppm.  It should be
noted that  the data shown  in Table  1-6  represent default mixed  waste characteristics  for
developing waste acceptance criteria for the Waste Isolation Pilot Plant (DOE90).

1.1.4 Incinerable Wastes

The  preceding information characterized in a general way the radioactive and  mixed wastes
generated or stored at LANL in support of DOE defense and research related activities.  To
provide a more in-depth understanding of the types and quantities of waste forms which will be
incinerated,  the following  focuses on the types of waste  which are known to be targeted for
incineration at LANL.
The characterization is based on several compilations of data gathered by DOE low-level and
mixed waste task groups, including a survey of DOE facilities that currently use incinerators or
plan to install new ones  (EGG88, DOE89,  HUT90).  As noted before, the actual distributions
of waste volumes and properties may change because of DOE's current activities associated
                                         1-10

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Table 1-6.    Approximate distribution and chemical constituent content of mixed waste forms
             (a)
Waste Form(b)
             Typical Distribution

Waste Form         Chemical Constituent
Quantity (wt-%)     Concentration (mg/Kg)(o)
  Cemented and
  uncemented aqueous:

  Cemented and
  uncemented organics:

  Immobilized process
  and laboratory solids:

  Combustibles:

  Metals:

  Spent Filters:

  Inorganic solids:

  Leaded rubber:
 36


 10


   1

 20

 25

   6

   1

   1
    10 - 700


50,000 - 150,000


    10-200

  750-2,000

   1,000,000

    50 - 150

  100 - 8,000

    600,000
(a)     Extracted from Tables B.3.1 and B.3.2, DOE/EIS-0026-FS, Vol. 2, Jan. 1990 (DOE90).
(b)     Chemical constituents typically include trichloroethane, carbon tetrachloride, trichloro-
       and trifluoethane, methylene chloride, methyl alcohol, xylene, butyl alcohol, acetone,
       toluene, PCBs, NaOH, etc.  Metals typically consist of cadmium, lead, etc.
(c)     Units represent mg of chemical constituents per Kg of waste form.
activities associated with the Environmental Restoration Program.  Also, DOE is in the process
of revising its low-level and mixed waste acceptance criteria; a similar revision is being done

for TRU waste (HUT90).  Accordingly, the following characterization gives only a snapshot
description of low-level and mixed waste disposal and treatment practices at LANL.
                                         1-11

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The current yearly mixed  waste generation rates  are  given  in Table 1-7 based on  1989
Department of Energy data for LANL (HUT90).  A review of Table 1-7 indicates that 305,000
Ibs/yr, or nearly 50 percent by  mass, of the waste  is generated in a liquid form.  About 35
percent of the total waste quantity is identified as mixed waste.  An additional source of waste,
not identified in this table, is contaminated soil; however, no data were provided about its
volume, quantity, and combustibility.  LANL estimates that about half of its waste is currently
in a combustible form (EGG88).

Under a new low-level and mixed-waste management program, LANL plans to establish onsite
treatment capabilities, increase  treatment capacities to meet newly anticipated  requirements,
separate TRU from non-TRU waste treatment processes, and develop more comprehensive waste
acceptance criteria (waste acceptance criteria have  been established  by DOE to regulate its
overall waste management activities and programs)  to handle new or additional LANL waste
streams (DOE89a, EGG88). Some of these wastes are targeted for incineration.

The waste forms and volumes or quantities for LANL are given in Table 1-8.  The  total low-level
waste volume inventory is 4,373 m3, which consists of  3,052 and  1,321 m3 of alpha and
beta/gamma wastes, respectively.  Mixed waste is comprised of 175 m3 of solid materials and
3,700 gallons of liquids.  The primary radionuclides are  reported to be isotopes of plutonium,
americium, curium, and tritium  and carbon-14.  Some fission products, such as  strontium, are
also present in  unspecified quantities.  The reported  concentrations  are cited relative to
established limits as defined by the DOE waste acceptance criteria. For example, the limit for
solid wastes is expressed in terms of exposure rate; i.e., less than 10 mr/h.  Alpha emitters are
expressed in terms of TRU concentration; i.e., less than 100 nanoCuries/gram. The maximum
radioactive concentrations for liquids are given as less than 0.1 microCurie/liter as total activity,
which is interpreted to apply only to beta/gamma emitter radionuclides.
                                         1-12

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Table 1-7.    Estimated yearly mixed waste volume and mass generation rate by physical forms
             forLANL(a)
Waste
SOLID:
LLW DAW
LLW
Mixed LLW
Mixed LLW
LIQUID:
Mixed
LLW oils
Grease
Forms

Not RCRA
Biological
Solids
Uranium
Total:

Stint, fluid
Not RCRA
Not RCRA
total:
Volume
(FtVyr)

15,000
600
29,000
350
44,950

500
4,600
700
5,800
Quantity
(Lbs/yr)

112,000
11,000
220,000
18,000
361,000

5,000
260,000
40,000
305,000
(a)  Extracted from Table I: Los  Alamos Combustible Radioactive  and Mixed  Waste
    Characterization (HUT90).

LLW = Low-Level Waste

DAW = Dry Active Waste
                                       1-13

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Table 1-8.    Summary  characterization of  waste  volumes, radiological properties, and
             inventory at LANL(a)
Characteristics
Volume or
Quantity (b)
Radiological
Properties(c)
Total LLW
 volume (m3):

Combustible
 fraction of LLW:

Low-level Combustible
9,436


    0.46
total volume (m3):
TRU:
Beta/gamma:
Mixed waste:
Solids (m3):
Liquids (gal.):
Total activity:
Total TRU:
4,373
3,052
1,321

175
3,700
—
<0.1 uCi/g
< 10 mr/h.

<0.1 uCi/g
<0.1uCi/L
<0.1 uCi/g
(a)  Extracted form Table 2-1, EGG-LLW-8269, October 1988 (EGG88).
(b)  All values are rounded off.
(c)  Primary radionuclides are reported to be Pu, Am, Cm, H-3,
    C-14, and fission products, such as Sr, and Ce.
                                        1-14

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1.2  COMBUSTION PROCESS AND RADIONUCLIDE EMISSIONS

1.2.1 Radionuclide Airborne Emissions

Waste may be introduced into an incinerator in a bulk material (e.g., as boxes, bags, or drums),
shredded, in a sludge form (e.g., slurry),  or injected as liquid (EGG88).   The feed rate is
governed by the combustible nature of the material and by the introduction of an additional
source of fuel.  Sometimes the waste, if in a liquid form, may be introduced as a mixture of fuel
and waste.  The waste/fuel ratio is determined by the combustion properties of the waste and
incinerator capacity.  The considerations noted above apply generally to all waste forms (mixed
and low-level wastes) introduced into incinerators. As combustion occurs, oxygen is consumed
and the combustion gases are entrained in the afterburner.   The proper combustion conditions
are maintained by controlling the amount of air, waste feed  rate, and temperature.  Special
attention is given to the residence time in order to ensure that complete oxidation occurs and that
the air/fuel mixing is also adequate for total combustion.

Eventually,  combustion  gases, suspended  particulates,  fumes, and products of incomplete
combustion are entrained in exhaust scrubbers and filtration devices before being released from
the stack. The chemical and radioactive constituents of the off-gas can vary significantly from
those of the input waste. The combustion process does not destroy trace metals or radioactivity,
nor does it change the rate of radioactive decay, but rather it changes only the chemical and
physical forms  of the radionuclides.

The most often encountered radionuclides, tritium, carbon,  and  iodine, are generally released
with little or no retention in the incinerator.  Such radionuclides form gases which retain their
radioactivity. Semivolatile elements, for example lead, polonium, sulfur, cesium, mercury, and
phosphorus, may, under oxidizing and reducing conditions, form volatile fumes even at moderate
combustion temperatures. At elevated temperatures, hydrochloric acid (HC1) produced from the
burning  of polyvinyl chloride, metals, and metal  oxides present in the waste may become
volatilized to various degrees (TRI89, RIN_, BAR_). The temperatures at which elements are
                                         1-15

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classified as volatile or semivolatile are dependent on the chemical form of the element and its
residence  time in the  combustion  chamber.  The amounts of trace  metal or metal oxides
volatilized depend on the partial pressures of O2, HC1, and H2O, the waste feed rate, the particle
surface area,  and off-gas flow rate.   Longer residence times,  normally required for  the
destruction of organic compounds, result in greater formation of metal oxide fumes (TRI89).
These fumes, generally less than 0.1 um in size, are usually exhausted out of the stack because
of their small size.  Radionuclides that volatilize at higher temperatures  will also become
entrained  in  their vapor form and coalesce  as particulates at  cooler temperatures.  Such
radionuclides will condense  onto suspended particles present in the exhaust stream forming
radioactive particulates which may have higher specific activities than the waste itself.

This process, known as enrichment, depends largely on the individual radionuclide, its behavior
at oxidizing temperatures and particle size distribution in the exhaust stream (UNS82, TRI89,
GAL__).  This process reflects the depletion of certain elements in the settling ash, the higher
surface to volume ratio of the fumes, and the surface reactivity of the fumes.  For example, coal
combustion in a coal-fired boiler has revealed varying enrichment factors, ranging from  1 to 2
for radium, uranium, or thorium.  Higher enrichment factors were observed for lead-210 and
polonium-210, typically ranging from 1 to 11 (UNS82).

Volatilized radionuclides may be readily removed  from the off-gas prior to discharge into the
atmosphere by simply cooling the gases.   Cooling causes the vapor to  condense out  of the
airstream and onto surfaces or into components. This deposition process is beneficial since it
reduces stack emissions, but is also detrimental since it may result in radionuclide deposition in
undesirable parts of the off-gas treatment system.   Preferably, the deposition should occur in
scrubbers, filters, or components designed for the collection and removal of fly-ash or fume
residues.  For TRU waste, the accumulation of fissile radionuclides at specific locations may
present a criticality problem (the condition in which a nuclear reaction is just self-sustaining)
(CARJ.. However, given the relatively low concentration of TRU waste, criticality safety should
not normally be a concern (IAE89).
                                         1-16

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Off-gas treatment typically involves passing the hot flue gases into a series of components to
remove suspended particulates, gases, and radionuclides. Such systems typically include heat-
exchangers, filters and separators, high efficiency particulate air (HEPA) filters, and adsorbers.
Other forms of off-gas cooling include quenching by water injection and dilution by introducing
air at ambient temperature.  Particulate emissions, depending  on particle sizes  and exhaust
velocity, are trapped in heat-exchangers, filters or electrostatic separators.

Typically, large particles, which are too heavy to be entrained by the exhaust stream, settle onto
surfaces or are trapped by the filters  and electrostatic separators.   As noted earlier, as the
temperature cools, vapors condense out of the airstream and deposit or impinge onto surfaces.
Smaller particles are entrained in the exhaust stream because of their smaller size and mass.
HEP A filters are designed to remove small particles,  typically with a collection efficiency of
99.97 percent for 0.3-um diameter particles (ERD76).  HEPA filters may be installed in tandem
with two or more units in series and are usually placed before the carbon adsorbers. Pre-filters
are also placed before the HEPA filters to prolong their useful lives.

Vapors and gases that have  not condensed out of the airstream may be  collected  by using
adsorbers;  e.g.,  carbon filters,  which  may be  treated  with potassium   iodide  (KI)  or
triethylenediamine (TEDA) for improved collection efficiency, typically ranging from 95 to 99
percent (ERD76).  Depending on the application, a second set of HEPA filters may be installed
beyond the carbon filters to trap what is known as "carbon fines," which may be released from
carbon granules.  Carbon fines may contain elevated radionuclide concentrations.  Sometimes
wet scrubbers are also installed to trap acid or organic  vapors (HC1, HF, NH3, SOX, and NO*)
from the exhaust stream. If wet scrubbers are installed, they are usually followed by demisters
and driers, which remove water vapors from the exhaust stream. Excess water vapors tend to
saturate HEPA filters and carbon adsorbers, rendering  them totally ineffective.

These off-gas components, when installed as one engineered system,  can provide very high
collection efficiencies.   The system reliability depends on how the system is  operated  and
maintained. The overall collection efficiency is also nuclide-dependent; for example, it is lower
                                          1-17

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for cesium than for plutonium.  Operating experience indicates that the overall collection
efficiencies of systems range widely. In a survey of operating facilities, an International Atomic
Energy Agency (IAEA) report cites efficiencies, expressed in terms of overall decontamination
factor (DP), ranging from as low as 10 to as high as 107 (IAE89).  (For treatment of hazardous
materials, incinerators are rated in terms of destruction and removal efficiencies, or DREs. The
DRE is an inappropriate concept for radioactive materials, since radiation is not destroyed by
the incineration process.)  The DF is expressed as the ratio of  the amount of radioactivity
introduced in the incinerator to the amount that is observed on the exit side of the final off-gas
treatment system component (e.g., HEPA filter or carbon adsorber).  A cluster of DFs were
noted ranging from 1O5 to 106.  A few facilities reported overall DFs ranging from about 10 to
104. It should be noted that the cited DFs represent different types of incinerator systems,
incinerators with different capacities, and varying waste forms and  radionuclide concentrations.
Finally, not all systems were similarly equipped with off-gas treatment systems.  Some facilities
were equipped with more elaborate off-gas treatment equipment than others.

Actual airborne radionuclide emissions are also known to vary for  the reasons given above.  In
addition,  many incinerators process waste with radiological and physical properties  that vary as
a function of time.  Accordingly, it is difficult to characterize emissions in generic terms.  A
general perspective on the type and extent of airborne emissions can, however, be obtained from
operating facilities.    Unfortunately,  little information exists  that  directly compares the
radiological properties of the waste introduced in the incinerator with actual airborne emissions.
Typically, data only summarize airborne emissions on a yearly basis, with no correlation with
waste throughput.
                                         1-18

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1.2.2  Radiological Properties of Ashes and Residues

The volume reduction of low-level  radioactive waste in  an incinerator results in  higher
concentrations  of radioactivity and higher radiation  levels in the end  product, ash, when
compared to the feed material.  System design (including building layout where appropriate)
should minimize personnel interaction with equipment and vessels that contain ash. Shielding
of ash collection bins and other ash handling equipment may also be needed.

The bulk of the feed material is consumed during the combustion process while a change in the
chemical form of the waste occurs. As the material is oxidized, certain compounds are formed,
typically sulphates, chlorides, fluorites, nitrates, phosphates, and metal oxides, depending upon
the waste.   In  a  rotary Mm, for example, as the combustion process occurs,  the ashes are
collected at the bottom of the kiln and the rotation of the kiln forces the ash to collect in
collection bins. Some of the ash, however, is entrained with the off-gas and settles or collects
in various parts of the off-gas treatment system.  The deposition of ash in various parts of the
system is dependent upon off-gas velocity, particle size and  density,  combustion   process,
residence  time, and  the  type of treatment  system components; e.g.,  filters, electrostatic
separators,  scrubbers, HEPA filters, carbon adsorbers.

The distribution of ash in various incinerator components is shown in Table 1-9.  The bulk (91
to 94 percent) of the ash is retained in collection devices at the point of combustion.  Smaller
amounts are retained in other sections  of the incinerator system, such as  the post-combustion
chamber (2-4 percent), filter  bags (1.5-5.2 percent),  and cyclone (1-3  percent).  Minimal
amounts, less than 2 percent, are retained on HEPA filters, cooling coils, and diffusers,  and
Other unspecified locations.
                                         1-19

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            Table 1-9.  Typical distribution of ash in incinerator components(a)
      Components
       Range of
Distribution (percent)
      Ash collection bin
      Post-combustion chamber
      Bag Filters
      Cyclone
      Diffuser
      Heat Exchangers
      HEPA filters
      Other miscel.
      locations
   91-94
     2-4
   1.5 - 5.2
     1-3
    ~  0.5
    ~ 0.4
    ~ 0.6

   0.04-2
(a)   Extracted from IAEA Technical Report Series No. 302, Appendix A, 1989 (IAE89).


The deposition of ash in various parts  of the incinerator,  other than in ash bins, is a potential

problem since the ash must be periodically removed.  Because ash contains radioactivity, now

present at a  higher  specific activity,  ash removal and  handling must be performed  under

controlled conditions. However, for some volatile radionuclides (e.g., tritium and iodine-125),
the ash may  contain only trace amounts or no radioactivity  at all.  Usually ash handling is

performed remotely, via a ram  or conveyor, and the  operator is separated from the ash by a

physical barrier. The ash is removed following an appropriate cool down period. The process

is also performed with proper ventilation to keep the ash from being dispersed in the immediate

area or from being  resuspended.   The ash may be discharged into  a glovebox  and chute
connected to  a drum. Ash may be dumped directly into its disposal containers or processed;

e.g., via cement, bitumen, or thermosetting resin solidification followed by packaging.


The amount of ash produced depends on the physical and chemical properties of the waste.  For

the type of waste to be processed by the LANL incinerator, volume-reduction ratios of about 10

to 25 are anticipated (NRC83).  The ashes typically consist of fine (80-90 percent)    and oaas

(clinkers) material (10-20 percent).  The density of fines and clinkers varies from about 0.9 to
                                         1-20

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 3.0 g/cm3. The chemical composition of ash fines varies as well, but typically consists of oxides
 and carbon compounds.  Oxides include SiO2, A12O3, CaO, TiO2 and lesser amounts of FeA,

 K20, MgO, Na20, and P2O5 (NRC83).  Oxides may make up about half of the total ash, by

 weight. The balance may be comprised of carbon compounds, chlorine, other metal oxides, and
 refractory material.
 Ash particle sizes vary from relatively large to small diameters.  About three -quarters of the
 ash particle sizes cluster around a 500- to 10-um particle diameter.  Only a few particles are

 above 500  or below 10 urn in size.  Ashes from solid and liquid wastes show only a small

 difference in particle size.  The following provides a breakdown of particle sizes for two types
 of waste streams (RFP82):
              Particle size
              Range (um)

               > 1000
              1000-500
               500-100
               100-20
                20-10
                 10-5
                5-0.5
                < 0.5
Weight % Distribution
Solids      Liquids
  2
  6
 20
 32
 25
 10
  4
 2
 3
10
55
22
 5
 2
Clinkers are typically several inches in length or diameter and at times may be found fused

together in large chunks. They are formed during the combustion of rubber, plastic, wood, or

resins, etc.  Clinkers may appear very sooty, and are also usually porous, about 30 to 50 percent

porosity.  Again,  these properties may vary depending on the  nature of the waste initially
introduced into the incinerator.


The radiological properties of ash depend on the initial amounts  of radioactivity present.  As

discussed, volatile radionuclides will not remain in ash residues.   Because of the volume

reduction  normally  encountered,  ash  will  have higher  specific  activities.   Radionuclide
                                         1-21

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concentrations may range from nondetectable levels to very high concentrations which require
special handling procedures. Other than the Toxicity Characteristic Leaching Procedure (TCLP)
test to simulate leaching of eight  metals (including lead, cadmium, mercury, chromium, and
barium) four pesticides, two herbicides, and 25 organic compounds (EPA90), ash is generally
believed to be free of other hazardous material properties. The distribution of radioactivity in

ashes is shown in Table 1-10 for a number of radionuclides.


              Table 1-10.  Typical radionuclide distribution in incinerator ash(a)
              Radionuclide
Distribution (percent)
              Pu
              Cs-137
              Cs-134
              Co-60
              Ag-llOm
              Ru-106
              Zn-65
              Sb-125
              Zr-95
              Sr-85
              Se-75
              Sc-46 (microspheres)
              1-125
              H-3
    77-82
     77
      8
      6
      3
      2
     1.5
     0.8
     0.3
      86
     0.3
    79-98
     < 1
     < 1
              (a)  Extracted from IAEA Technical Report Series No. 302, Appendix A,  1989
                   (IAE89), HPS Vol. 44, No.  6  (LAN83), Waste Management-85  (WM85),
                   and DOE/LLW-12T, Nov. 82 (EGG82).


 There is a problem inherent in characterizing radionuclide distributions and concentrations in
 ashes. The presence of radionuclides in ash is highly dependent on the sequence of the burn and
 the material that is initially radioactive.  The ash will settle according  to physical properties
 (e.g., particle size and density) (EGG82, LAN83, WM85).  Accordingly, the
                                           1-22

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 radioactivity in the ash will also be layered during the combustion process until the ash is
 physically removed.

 The ash removal system will disturb this distribution by stirring and mixing the ash, in effect
 diluting the radioactivity over a larger  ash volume.  Experience has shown that it is not
 uncommon to have discrepancies on the order of 20 to 50 percent when attempting to account
 for the distribution of radioactivity (EGG82, LAN83, WM85).  As noted earlier, this aspect is
 further complicated by ash that settles or deposits in other parts of the system and by the smaller
 amount released through the exhaust stack.

 Among the principal  factors to be considered in evaluating  the environmental  impacts of
 radioactive ash disposal are worker radiation exposures  and exposures to the public due to
 transportation to the disposal site.  Additionally,  the impact of disposal of the original  feed
 material should be considered by comparison.  In some instances, the presence  of RCRA-
 regulated  materials in the feed material would prohibit the land  disposal of the waste material,
 resulting in possibly prolonged storage.

 NRC regulations governing acceptable forms for land disposal of low-level waste are contained
 in 10 CFR 61.  Solidification of the radioactive ash is required prior to shipment for disposal.
 Department of Transportation regulations which govern the packaging, preparation for shipment,
 and transportation of radioactive waste are contained in 49 CFR 173, Subpart I.  Additional State
 regulations may apply, depending on the disposal site to be used.

 Currently  there are only three approved commercial disposal sites in the United States for low-
 level radioactive waste: Barnwell, South Carolina; Beatty, Nevada; and Richland, Washington.
 Others are expected to be opened in the early 1990s to meet the requirements of the Low-Level
Waste Policy Act Amendments of 1985.  Disposal of government waste may be permitted at
selected federally owned sites.
                                         1-23

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1.3
INCINERATOR POPULATION
Although the historical operating experience base is still quite limited for radioactive and mixed
waste incineration, the shrinking availability of publicly acceptable means of waste disposal and
subsequent need to minimize waste quantities are generating increased efforts to use incineration
to reduce the volume and hazardous chemical content of waste material.  This section discusses
some of the radioactive/mixed waste incinerators now in use or under consideration.

Operable incinerators are located at four U.S. Department of Energy (DOE) facilities. These
are the controlled air incinerator at the Los Alamos National Laboratory (LANL), the Oak Ridge
Toxic Substances Control Act (TSCA) incinerator, the Rocky Flats Plant (RFP) fluidized bed
incinerator, and  the  Idaho  National  Engineering Laboratory  (INEL) Waste  Experimental
Reduction Facility  (WERF).   Schematics of these incinerators are  provided in Figures  1-1
through 1-4.  Additionally, a new controlled air incinerator is planned for LANL, and a rotary
kiln incinerator  (the Consolidated Incineration Facility, or GIF) is planned for the Savannah
River Site.  The Savannah River Site Beta-Gamma  incinerator,  shown in Figure 1-5, was
 shutdown  several years ago for equipment modifications.   When the GIF was approved,
 modification of the Beta-Gamma incinerator was canceled, and there are no plans to restart this
 unit.  DOE  has discontinued  work at the INEL Process Experimental Pilot Plant (PREPP)
 incinerator shown in Figure 1-6, while evaluating its future role in the DOE Waste Management
 Program.

 A low-level radioactive waste incinerator owned and operated by the  Scientific Ecology Group,
 Inc. (SEG)  in  Oak  Ridge,  Tennessee,  began commercial  operation in 1989.  The SEG
 incinerator, shown in Figure 1-7, is an automatically controlled partial-pyrolysis unit, based on
 the Swedish Studsvik incinerator, which has been in service since 1976.
                                          1-24

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              ©
  1. Multiple Energy Gamma Assay
    System (MEGAS)

  2. Micro-dose x-ray waste package
    scanner

  3. Waste receiving glovebox with air-
    lock entry

  4. Side ram feeder

  5. Main ram feeder


 6. Combustion fuel/air supply glovebox

 7. Incinerator ignition (primary) chamber


 8. Inter chamber

 9. Incinerator combustion (secondary)
    chamber

10. Incinerator chamber access
   gloveboxes

11. Quench column


12. High-energy venturi scrubber
 13. Packed column scrubber


 14. Off-gas demister


 15. Off-gas superheater


 16. HEPA filters (first and second stages)

 17. Activated carbon adsorber


 18. HEPA filter (third stage)

 19. Off-gas monitoring (CO, COj, H2O)
    station

20. Continuous stack sample system

21. Continuous stack sample system


22. Facility and process vent stack
23. Scrub-water primary coolant heat
   exchanger
 24. Isolated secondary coolant loop heat
     exchanger

 25. Scrub-water hydrocyclone particulate
     separator

 26. Scrub-water recirculating sump tank
 27. Scrub-water blowdown filters

 28. Facility liquid sump tank and transfer
    system

 29. Gravity ash-removal hopper

 30. Ash-removal valves


.31. Ash-removal drum system

 32. Process instrumentation and control
    panels
                     Figure 1-1.  The Los Alamos Controlled Air Incinerator

                                                       1-25

-------
               INCINERATOR
                                                           OFF-GAS HANDLING
      SOUDS SHREDDER

SOLID WASTES  T  FINELY DIVIDED
TOOESHREDOED-i  SOLID WASTES
  DNIZMG
WET SCRUBBER
                                                                      PACKED
                                                                      COLUMN
                                                                     SCRUBBER
                                                               VENTURI  /
                                                               SCRUBBER
  Figure 1-2.  The Oak Ridge Toxic Substances Control Act (TSCA) Incinerator

                                        1-26

-------
Figure 1-3.  The Rocky Flats Fluidized Bed Incinerator




                        1-27

-------
                              Incinerator
                              room*"
                                      Dilution
                                      air blower
x.r«r
•lion Sytlem

  Radiation
     WetoM
    D
                                                                                   Drum
                                         Drum
                   Figure 1-4.  The INEL Waste Experimental Reduction Facility

                                                  1-28

-------
               SECONDARY
INTERNAL
    RAM
SPRAY
QUENCH


BAG
HOUSE
                                                                            10 BLOWERS
         SOLVENT
          FEED
          TANK
5S-GAL
DflUMS
             Figure 1-5.  The Savannah River Site Beta-Gamma Incinerator

                                         1-29

-------
                                                                            Stack]
     Quencher
                               Venturi
                               scrubber

v-_
^



0

c
L

Off-gas flow
                                    Entrapment
                                    eliminator
                                           Induced
                                           dranfan'
                                                  Mist eliminator
                                      Reheater   HE PA
                                                 filters
          Carbon monoxide monitor
                     O2 monitor
Receiving
and
shipping
Rotary kiln
                                         Surge
                                         recycle tank
             Secondary
             combustion
             chamber
HO
                    Residue   Trommel
                    cooler     separator
                                                        Inspection
                                                        and
                                                        shipping
                                         Fine
                                         ash
                                         storage
                                                   iCement
                         Figure 1-6.  The INEL PREPP Incinerator

                                           1-30

-------
sixoe
    Figure 1-7.  The Scientific Ecology Group (SEG) Incinerator




                              1-31

-------
Advanced Nuclear Fuels, in Richland, Washington,  operates a dual-chamber controlled-air
incinerator for processing solid and liquid wastes contaminated with uranium.  The incinerator
has operated since October 1988. The wastes incinerated originate during the manufacture and
recovery of nuclear fuel materials.

A commercial  unit for  thermal destruction of mixed waste was  permitted in  1990,  and is
expected to begin operation in early 1991.   This unit, owned and operated by Diversified
Scientific Services, Inc. (DSSI), in Kingston, Tennessee, is designed to use mixed waste, in fluid
form only, as beneficial fuels in a boiler system.  DSSI notes that most of the waste will come
from hospitals  and universities where various  short-lived radionuclides are used,
and that most of the radioactivity will have decayed  away before the waste is processed  and
received by DSSI.  The boiler system is designed for  complete thermal destruction of the fuels
and recovery and reuse of the energy produced.

Two electric utility companies investigated incineration for volume reduction of waste produced
at their nuclear generating stations. Duke Power Company installed a fluidized bed incinerator
at its Oconee Nuclear Station in South Carolina. Changes in station operating procedures made
 subsequent to the installation of the incinerator changed the potential incinerator feed material
 from that originally contemplated. The consequent need for design modifications, and associated
 delays, resulted in a decision to defer final
 completion and operation of the incinerator for an undetermined period. The incinerator is being
 maintained in a layup condition pending a future decision to reactivate. Duke Power now uses
 the  SEG  incinerator  described  above  for  its  incineration  needs (DTJK85,  DUK90).
 Commonwealth Edison Company installed fluidized bed incinerators similar to the Duke Power
 unit at its Byron and Braidwood nuclear stations.  These incinerators are also currently in layup.

 Table 1-11 summarizes  the  location,  type, status, and waste  processed for each of the
 incinerators described above.
                                            1-32

-------
          Table 1-11. Status of selected U. S. radioactive and mixed waste incinerators
Operator/
Location
DOE/
Rocky Flats

DOE/
SRS Beta-Gamna
DOE/
SRS CIF

DOE/
1 AUI f*A T
LANL CAI

DOE/
LANL LLU/HW
DOE/
INEL UERF

DOE/
INEL PREPP
DOE/
TSCA
Oak Ridge, TN
BNL/HWHF
Brookhaven, NY
Commercial
SEG/
Oak Ridge, TN
DSSI/
Kingston, TN
ANF/
Richland, WA
Type of
Incinerator
Fluidized Bed

Stationary Hearth
Rotary Kiln

Controlled Air


Controlled Air
Controlled Air

Rotary Kiln
Rotary Kiln
Stationary Hearth

Controlled Air
Boiler

Controlled Air
Status
Shutdown -
to be upgraded for
RCRA permitting
Shutdown - Restart
not planned
RCRA Part B permit
submitted 1988. Planned
operation in 1993.
RCRA, TSCA permitted.
shutdown pending EIS.
Planned restart in 1991.
Planned operation in 1997.
Operating under interim
status. RCRA Part B permit
submitted.
Planned operation under
evaluation
Testing, tentative
operation 1991
Operating. Not RCRA permitted

Operating
Planned operation 1991

Operating
Waste
Stream
3,4,8 (no PCBs)
10

1. 2
3, 4, 9

1,2,3,4,5,
6,7,8,9,10
(liquids only)
1. 2, 3, 4
1, 2, 3, 4

5, 6
1, 2, 3, 4, 10
11

1
3

1?
Design
Capacity
(kg/h)
93

182
919

57


181
181


1043
34

727
2 gal/m


Duke Power/
Oconee Nuclear Station

Commonwealth Edison/
Byron and Braidwood
Nuclear Stations

Waste Stream Codes

TRU = Transuranic Waste
LLW = Low-Level Waste
 HW = Mixed Waste
Code
        Waste
Fluidized Bed


Fluidized Bed
1
2
3
4
5
6
LLW Liquids
LLW Solids
LLW/HW Liquids
LLW/MW Solids
TRU Liquids
TRU Solids
7
8
9
10
11
Lay-up


Lay-up
1, 2


1. 2
                                         Code     Waste

                                                  TRU/HW Liquids
                                                  TRU/MU Solids
                                                  Non-Radioactive  Hazardous Wastes
                                                  Wastes can  contain PCBs, except as noted
                                                  Very low-IeveI radioactive nuclear
                                                  medicine  wastes  and autoclaved medical wastes
                                         12       Liquid and  solid wastes contaminated with U
                                                 1-33

-------
A number of smaller scale incinerators are used by medical facilities and other institutions to
process radioactive waste.   Using data from the CRCPD  survey and assumptions  about
nonrespondents, it is estimated that nearly 200 licensees incinerated about 300,000 cubic feet of
low-level radioactive waste in 1984.

International incineration experience was briefly reviewed during this project.  A detailed review
of international experience is beyond the scope of this project.  Table 1-12 lists location, type,
design, capacity,  and waste  stream content for operational large scale foreign incinerators. A
survey of the operating history of several European facilities indicates that releases and offsite
exposures are well within established limits  (IAE89).  Typically, reported airborne releases
range  from nondetectable levels to nearly one percent of the imposed limits.  Most of the
problems associated  with  incinerator  operations have,  however,  been  experienced with
operational  reliability and maintenance  (IAE89).  Such problems typically include:   frequent
replacement of off-gas treatment 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, potential fires in filter
systems, and humidity control and HEPA filter clogging.  Such problems have also resulted in
higher operating  costs.

One incinerator research project, being  conducted under the  Superfund Innovative Technology
Evaluation (SITE) Program, has potential application to radioactive and mixed waste treatment
(ESC89).  This project, the Plasma Centrifugal Reactor, utilizes high temperatures (exceeding
2800°F) generated by a 600-Kw plasma arc torch to  volatilize organic components and
encapsulate heavy metal components in a glassy slag.  The volatile metals are captured within
an  offgas  treatment system.  Liquid and solid organic  compounds can be treated by this
technology, and  it is  most appropriate for  soils and  sludges contaminated  with metals and
difficult to  destroy organic compounds.
                                          1-34

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Table 1-12.  International operational large-scale incinerators

Country
Austria
Belgium





Canada


France





Germany




Germany

Japan


Sweden
UK




Italy

Location
Research Centre
(Seibersdorf)
Research Centre
(Mol)




Bruce

Chalk River
Reprocessign plant
(Marcoule)
Research Centres
(Fontenay-aux-
Roxes)

-------
Phase HI testing, originally scheduled for late 1990, was designed to determine the applicability,
operability, and reliability of the system when processing DOE waste.  During the tests, waste
materials were to simulate Idaho National Engineering Laboratory (INEL) radioactive and mixed
wastes. These tests were, however, delayed because of inappropriate funding (RET90). In the
interim, RETECH is planning  a full scale demonstration  at a chemical  plant located  in
Switzerland.  The demonstration tests will be followed by commercial operation at this Swiss
company. The plasma centrifugal reactor will be designed to accommodate 55 gallon drums into
the reactor chamber.  Operational test results are expected to become available in early  1991
(RET90).

 1.4 OPERATIONAL INCINERATOR EMISSIONS

 1.4.1  DOE Incinerators

 The following presents information characterizing radionuclide emissions for a few  DOE and
 two commercial facility incinerators.  For DOE incinerators, the information is based on DOE
 data prepared in response to NESHAPS reporting requirements under 40 CFR 61.94.  The DOE
 compiles, on a yearly basis, such data in the Effluent Information System - EPA Release Point
 Analysis Report, a computerized  database.  For the commercial facilities, the information is
 extracted from technical correspondence.

 The DOE reports provide aggregate data on airborne effluent releases  by  radionuclides and
 emission sources (e.g., buildings, areas, or stacks).  In some instances, the release points include
 more  than one emission  source  for a given stack or building.   The DOE reports do not,
 however, present any information characterizing each incinerator emission source contributing
 to total releases. Furthermore, these reports do not typically provide any information describing
 the activities  or  waste  streams  which contribute to overall emissions.    Any information
 characterizing waste forms and waste volumes was obtained, whenever available, separately from
 each DOE facility.
                                          1-36

-------
The tabulations which follow also provide estimates of yearly average airborne concentrations
released from the point of discharge into the atmosphere, but not at off site locations.  Offsite
concentrations vary depending upon atmospheric dispersion at specific downwind distances and
receptor locations.  Accordingly, offsite airborne concentrations would be still lower than those
shown in the enclosed tables.

Finally, it should be recognized that the information presented below characterizes activities and
emissions which may have since been discontinued or represents waste forms or streams which
are no longer  generated.  Similarly,  some incinerators may have  since been modified and
retrofitted with newer or better off-gas treatment technology, or totally taken out of service.
Accordingly, the information which follows provides only a snap-shot characterization of past
waste processing activities and associated airborne radionuclide emissions.

1.4.1.1  Rocky Flats Fluidized-Bed Incinerator.  The DOE Rocky Flats facility operates a
fluidized bed incinerator (FBI) designed to recover plutonium from bulk waste. The incinerator
is located in Building 776 and its off-gas treatment exhaust is released into a common system,
Building 776-202 plenum.

The off-gas treatment system is comprised of several components.  These components include:
a set of sintered metal filters; a process gas heatexchanger; and a four-stage HEPA filter.
Exhaust emissions are monitored by pulling a continuous sample through a paniculate filter and
an air monitoring and sampling station.

The FBI has never been used in  a continuous operating mode.  It has only been used for
intermittent tests conducted over a two-year period (LUK90). Three tests  were performed to
evaluate the FBI while using radioactive waste.  Two tests were conducted in 1979 and another
one was  done in  1980. The data associated with these tests are very limited in details, other
than indicating that Pu was the suspected radioactive contaminant in the waste.  No specific
radioisotopes  were  identified (e.g.,  as Pu-239,  Pu-240,  Pu-241,  etc.).   Radionuclide
                                          1-37

-------
concentrations were reported to be at very low concentrations, at less than 10 nCi/g. Some of
the relevant parameters characterizing these runs are shown below:
Test
Run No.
3
4
5
Ending
Date
6/79
8/79
8/80
Waste
Weight(lbs)
1,411
7,011
5,132
Waste Weight
Reduction
4.0:1
• —
4.0:1
Waste Volume
Reduction
—
—
23:1
Extracted from DOE/RFP submittal dated 10/29/90 (LUK90)
Airborne radionuclide emissions for three years, 1986 to 1988, for all releases associated with
the Bldg 776-202 plenum are listed in Table 1-13.  The data, however, do not indicate how
much of the radioactivity released is due to other building activities or processes.  This is
because the FBI exhaust is fed into a larger system  which services Bldg 776.  Emissions are
sampled beyond the point of confluence of the two exhaust systems.   This feature makes it
difficult to resolve emissions originating only from the FBI.

A review of Table 1-13 indicates  that five radionuclides comprise a major fraction (23 to 55
percent for any single year) of the reported emissions.  These nuclides are Pu-239, Pu-240, U-
233, U-234, and U-238. Table 1-14 presents yearly average stack concentrations based on the
previously cited yearly releases and given total air volume discharges.  The resulting emissions
represent  stack radionuclide  concentrations  and  not  offsite airborne radioactivity.   Stack
concentrations have decreased over the three reported years, except for Pu-239/Pu-240 and U-
238 which have remained relatively stable.
                                          1-38

-------
             Table 1-13.  Rocky Flats fluidized-bed incinerator emissions00
          Radionuclides
1986
             Yearly Releases - Ci/yr00
                    1987
1988
Am-241
Pu-238
Pu-239
Pu-239-240
U-233-234
U-238
5.1E-09
1.2E-09
O.OE-OO
1.9E-08
2.7E-09
1.5E-08
5.7E-09
4.3E-1O
2.1E-08
O.OE-OO
1.4E-08
1.3E-08
2.4E-09
2.2E-1O
O.OE-OO
1.7E-08
5.5E-1O
1.1E-08
(a)   Extracted from the U.S. Department of Energy, Effluent Information  System - EPA
     Effluent Analysis Report For Calendar Years 1986 to 1988, run date 9/18/89.
(b)   All values are rounded off and entered as exponential notation; i.e., 5.1E-09 means
     S.lxlO-9.
                  Table 1-14.  Rocky Flats fluidized-bed incinerator stack
                              radionuclide concentrations00
          Radionuclides
      Average Yearly Concentrations

1986                1987
                                        1988
Am-241
Pu-238
Pu-239
Pu-239-240
U-233-234
U-238
6.7E-17
1.6E-17
O.OE-OO
2.5E-16
3.6E-17
1.9E-16
6.4E-17
4.8E-18
2.4E-16
O.OE-OO
1.6E-16
1.4E-16
4.1E-17
3.7E-18
O.OE-OO
2.9E-16
9.4E-18
1.9E-16
(a)  Derived from the U.S. Department of Energy, Effluent Information System - computer run
    AFGHE776008A,  8/9/90.
(b)  Values  shown represent stack concentrations and not offsite airborne activity. Total air
    volume discharged through stack is 7.6E+7, 8.9E+7, and 5.8E+7 m3 for 1986, 1987, and
    1988, respectively. All values are rounded off and entered as exponential notation; i.e.,
    6.7E-17 means 6.7xlO-17
                                         1-39

-------
1.4.1.2 Los Alamos Controlled Air Incinerator.  The Los Alamos Controlled Air Incinerator
(CAT)  was  designed and built  to process waste containing transuranics and  mixed-fission
products.  The incinerator is in Building 37, which is located in Technical Area 50.

Incinerator off-gases are exhausted in a common stack, which also  services  other areas of
Building 37.  This feature makes it difficult to resolve emissions originating only from the CAI.
The CAI  off-gas treatment system is comprised  of several  components.  These components
include:   a water-spray  quench column;  a venturi scrubber;  a packed  column absorber; a
superheater; a set of primary HEPA filters; an activated carbon-bed; and a final set of HEPA
filters.

The stack monitoring system  pulls samples near the stack's exit point.  Air samples  are
continuously taken whether the CAI is operating or not. The samples are drawn, under pseudo-
kinetic conditions (i.e.,  using  a fixed rather than variable sampling flow rate),  through a
particulate filter.  The filter is changed and analyzed weekly.   Radiological analyses  are
performed using laboratory procedures. Los Alamos is currently considering the installation of
an on-line alpha/beta monitoring system distributed by EG&G/Ortec.  This monitoring system,
of European design, can differentiate between naturally occurring radioactivity (i.e., radon and
thoron decay products) and alpha emitters of interest (e.g., Pu-239, Am-241, etc.).

Four-year summaries of airborne emissions are shown in Tables  1-15 and  1-16.  Table 1-15
presents stack release data for 1985 to 1988. Plutonium releases  make up a small fraction (a
few percent) of total releases.  Mixed-fission products comprise about 98 percent of the total
emissions being reported by the LANL.  Yearly average stack concentrations, based on  the
previously cited yearly releases, are shown in Table 1-16. The resulting airborne concentrations
represent  only stack radionuclide emissions and not offsite airborne radioactivity.  In general,
mixed fission products and plutonium emissions have fluctuated about the limits of detection
from year to year.
                                          1-40

-------
                 Table 1-15.  LANL controlled air incinerator emissions^
                                 (Four-Year Summary)
    Radionuclides
    Pu-238-239
1985
Yearly Releases - Ci/yr^

1986         1987          1988
Mixed-fission
products
1.8E-07
1.9E-06
1.6E-06
7.6E-07
1.4E-07
1.7E-08
2.3E-08
(a)  Extracted from  the U.S. Department of Energy,  Effluent Information System  - EPA
    Effluent Analysis Report For Calendar Years 1986 to 1988, run date 9/18/89 and paper
    titled: The Los Alamos Controlled Air Incinerator for Transuranic and Chemical Waste,
    Table titled - TA-50-37 Controlled Air Incinerator: Total Airborne Radioactive Emission
    History, not dated.
(b)  All values are rounded off and entered as exponential notation; i.e., 1.8E-07 means 1.8x10"
    7
(c)  Denotes results at or below the limits of detection.
          Table 1-16. LANL  controlled  air incinerator stack radionuclide concentrations00
                     (Four-Year Summary)
Average Yearly Concentrations - uCi/cc^
Radionuclides
Mixed-fission
products
Pu-238-239
1985
-(c)
3.7E-15
1986 1987
l.OE-14 7.4E-15
9.0E-17 — (c)
1988
5.6E-15
1.7E-16
a)  Derived from the U.S. Department of Energy, Effluent Information System - computer run
    ALDET001006A, 8/9/90.
(b) Values  shown represent stack concentrations and not offsite airborne activity.  Total air
    volume discharged through stack is 1.9E+8, 2.1E+8, and 1.4E+8 m3 for 1986, 1987, and
    1988, respectively. All values are rounded off as exponential notation; i.e., l.OE-14 means
    l.OxlO'14.
(c) Denotes results at or below the limits of detection.

                                         1-41

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More detailed breakdowns of LANL radioactive emissions, stack concentrations, and waste
volume throughputs are shown in Tables 1-17, 1-18, and 1-19, respectively. This information
and data characterize  waste incineration practices from 1979  to  1990.  A review  of  this
information indicates that operational practices, incineration schedules, radionuclide distributions,
activity levels, and waste volumes vary significantly from year to year.  Nevertheless, it can be
noted that radionuclide emissions are relatively insensitive to waste characteristics in view of past
incineration practices.

1.4.1.3  Oak Ridge TSCA Incinerator.  The Oak Ridge TSCA incinerator was designed to
process uranium contaminated  and hazardous organic wastes in compliance  with the Toxic
Substance Control Act (TSCA).  Other forms of more traditional waste, e.g., LLW, are also
incinerated at this facility. The incinerator is located in a dedicated facility (K-1435), which is
part of the Oak Ridge Gaseous Diffusion Plant, which is designated as K-25.

Off-gas emissions are treated before being released out of the stack. The three major components
of the offgas treatment system are the venturi scrubber, packed-column scrubber, and a wet-
scrubber (ionizing). Emissions are continually monitored by an isokinetic sampling system. The
sampling train consists of a particulate filter and a series of impinger and  drying tubes. The
sample is conditioned in order to minimize sample losses.  Samples are (c) collected on a  weekly
basis  and the sampling probe, filter, impingers, and  drying tubes are subjected to laboratory
analyses  for specific radionuclides of interest.

Pre-operational testing was conducted in August and September 1988. Routine operations were
started later in the fall and were conducted intermittently to primarily test and evaluate
equipment performance and operating conditions.

Airborne emissions for the TSCA incinerator are shown in Table 1-20. As can be seen, data are
available only for 1988 and for radionuclides which were used to conduct the trial burns. Some
waste was, however, incinerated following the completion of the trial tests. Radionuclides
                                          1-42

-------
             Table 1-17.  LANL Bldg-37 (including CAT) Pu-239 stack releases(a)
       Releases®
    Year Ending/Period
                             Activity
                             Released (Ci)
                          Stack®
                   Concentrations (uCi/mL)
1980:    5/16-6/13
1981:    10/31-11/27
1982:
4/16-5/14
8/6-9/3
9/3-10/1
4.0E-09

1.2E-07

8.0E-09
1.3E-08
2.7E-08
6.1E-17

7.3E-15

5.0E-16
7.9E-16
1.6E-15
1983: 3/11-3/18
1985: 12/28-1/4
1/25-2/1
3/15-3/22
3/22-3/29
6/21-6/28
11/15-11/22
11/27-12/6
12/6-12/13
1986: 11/21-11/26
1989: 12/23-1/3
3/24-3/31
7/7-7/14
12/15-12/22
(a) Extracted from U.S. Depai
values are rounded off and
(b) For the years 1984, 1987,
detection.
1.5E-08
1.5E-08
2.3E-08
1.9E-08
1.2E-O8
1.5E-08
9.0E-09
1.5E-08
1.5E-08
1.7E-08
1.2E-08
1.4E-08
1.7E-08
4.0E-08
tment of Energy/LANL submittal dated
entered as exponential notation; i.e. , 4.
and 1988, all reported releases are at

3.7E-15
3.7E-15
5.6E-15
4.7E-15
2.9E-15
3.7E-15
2.1E-15
2.9E-15
3.7E-15
5.7E-15
2.9E-15
5.2E-45
6.5E-15
1.5E-14
11/9/90 (PUC9
OE-09 means 4.














10). All
OxlO-9.
or below the limits of


(c) Values shown represent stack concentrations and not offsite airborne radioactivity.
                                        1-43

-------
Table 1-18. LANL Bldg-37 (including CAI) mixed fission products
                      (beta) stack releases00
Releases®
Year Ending/Period
1981:




1982:
















1983:

1986:





1987:





7/10-8/7
8/7-9/4
10/2-10/30
10/31-11/27
11/27-12/25
12/31-1/8
12/25-1/22
1/22-2/19
2/19-3/19
3/19-4/16
4/16-5/14
4/2-4/9
5/7-5/14
5/14-6/11
6/11-6/18
8/13-8/16
6/11-7/9
7/9-8/6
8/6-9/3
10/1-10/29
10/29-11/26
11/26-12/31
3/11-3/18
6/24-7/1
4/25-5/30
5/30-10/3
6/27-10/3
10/10-11/7
11/7-12/12
12/12-1/23/87
1/23-2/27
2/27-4/3
3/20-3/27
4/3-5/8
5/8-5/29
7/31-9/4
Activity
Released (Ci)
3.1E-08
3.4E-08
5.8E-07
7.6E-08
8.3E-08
l.OE-08
6.8E-08
8.3E-08
9.3E-08
9.1E-08
1.8E-06
1.9E-08
5.9E-08
1.5E-07
1.5E-08
1.1E-08
6.5E-08
1.4E-OB
7.6E-08
3.2E-08
2.7E-08
9.5E-08
3.5E-08
2.7E-08
2.1E-07
5.2E-OB
3.2E-08
l.OE-07
1.4E-07
1.2E-07
1.3E-07
1.2E-07
2.1E-08
1.1E-07
6.3E-08
1.2E-07
Stack(c>
Concentrations (uCi/mL)
2.5E-15
2.1E-15
3.5E-14
4.6E-15
5.0E-15
2.2E-15
3.9E-15
5.0E-15
5.6E-15
5.6E-15
1.1E-15
4.6E-15
1.4E-14
9.1E-15
3.8E-15
6.4E-15
4.0E-15
8.5E-16
4.6E-15
1.9E-15
1.8E-15
4.5E-15
8.5E-15
6.6E-15
2.6E-14
7.1E-16
5.6E-16
6.2E-15
6.7E-15
5.0E-15
6.5E-15
5.9E-15
5.1E-15
5.5E-15
5.1E-15
6.0E-15
                               1-44

-------
                  Table 1-18. LANL Bldg-37 (including CAI) mixed fission products
                             (beta) stack releases(a)  (continued)
Releases®
Year Ending/Period
1987:



1988:








1989:






9/4-10/4
10/9-11/13
11/13-12/18
12/18-1/22/88
1/22-2/26
2/26-4/1
4/1-5/6
5/6-6/10
6/10-7/15
7/15-8/19
8/19-9/23
10/28-12/2
12/2-1/3/8
1/6-2/3
2/3-3/10
3/10-4/14
4/14-5/19
6/23-7/28
7/28-9/1
9/1-10/6
Activity
Released (Ci)
2.2E-07
1.4E-07
2.2E-07
2.0E-07
1.6E-07
5.9E-08
9.8E-08
1.7E-07
6.0E-08
9.2E-08
3.4E-08
2.5E-08
1.3E-08
1.1E-07
3.3E-OB
1.4E-07
3.3E-08
7.0E-08
9.0E-09
1.1E-07
Stack(c)
Concentrations (uCi/mL)
1.1E-14
9.4E-15
l.OE-14
1.1E-14
1.2E-14
4.5E-15
7.4E-15
1.3E-14
4.6E-15
7.0E-15
2.6E-15
1.9E-15
l.OE-15
9.6E-15
2.5E-15
l.OE-14
2.5E-15
5.4E-15
8.3E-16
8.2E-15
(a)  Extracted from U.S. Department of Energy/LANL submittal dated 11/9/90 (PUC90). All
    values are rounded off and entered as exponential notation; i.e., 3.1E-08 means 3.1xia8.
(b)  For the years 1984 and 1985, all reported releases are at or below the limits of detection.
(c)  Values shown represent stack concentrations and not offsite airborne radioactivity.
                                         1-45

-------
          Table 1-19.  LANL controlled air incinerator radioactive throughputs00
Date0*
Processed
12/7/79
4/7/80
4/28/80
7/6/81
8/15/82
9/6/84
9/23/86
3/24/87
Nuclides
Pu-239,Am-241
Pu-239,Am-241
Pu-239,Am-241
1-131
Cs-137,Ru-103,
Fe-59,Co-60
1-131
Cs-137,Ru-103,
Fe-59,Co-60
Pu-239,Am-241
Pu-239,Am-241
Beta emitters
Activity (Ci)
<2.3E-04
8.0E-05
4.5E-03
1.6E-02
4.0E-03
1.6E-02
4.0E-03
7.1E-02
1.4E-O1
6.2E-02
Total Waste(c)
Quantity (kg)
229
5
277
290
145
145
145
100
448
989
(a) Extracted from U.S. Department of Energy/LANL submittal dated 11/9/90 (PUC90). All
   values are rounded off and entered as exponential notation; i.e., 2.3E-04 means 2.3X104.
(b) No data available for the years 1983,  1985, and 1988.
(c) Values represent total waste quantities incinerated for the given dates. Radioactivity may in
   fact be contained in smaller waste volumes, typically less than 1 percent.
                                         1-46

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               Table 1-20. Oak Ridge TSCA incinerator emissions and waste feed
                           radioactivity for 1988(a)
Radionuclides
Tc-99
U-234
U-235
U-238
Total-U
Th-228
Th-230
Np-237
Pu-238
Pu-239
Emissions - Ci/yr00
1.6E-03
4.9E-04
2.5E-05
5.7E-04
ND
ND
ND
ND
ND
ND
Waste Feed - Ci(c)
9.5E-05
ND(d)
ND
ND
4.0E-02
l.OE-06
8.8E-07
1.4E-07
4.8E-07
4.8E-07
 (a)   Extracted from the U.S.  Department  of Energy, Effluent Information System  -  EPA
      Effluent Analysis Report For Calendar  Years 1986 to 1988, run date of 9/18/89.
 (b)   All  values are rounded off and entered as  exponential notation; i.e.,   1.6E-03 means
      1.6X103.

 (c)   Associated waste volume: solid waste, 160 cubic feet; liquid waste,        20,490 gallons
      Extracted from DOE 10/5/90 submitted.. ..
 (d)   ND  means no data.
 percent for each of the remaining two uranium isotopes. These reported radionuclide emissions

 are associated with the processing of 160 cubic feet of solid waste and 20,490 gallons of liquid

 waste.



 Stack radionuclide concentrations, based on the previously cited yearly releases, are shown in

 Table 1-21 for 1988 only.  The incinerator  was not operating  in the previous years.  The

 resulting airborne concentrations reflect primarily test burn trials and do not represent stack

 offsite airborne radioactivity.



.1.4.1.4   Brookhaven National  Laboratory  LLW Incinerator.   The Brookhaven National

 Laboratory (BNL) incinerator is located in the Hazardous Waste Management Facility (Bldg
                                          1-47

-------
             Table 1-21.  Oak Ridge TSCA incinerator stack radionuclide
                          concentrations - 1988(a)
             Radionuclides
       Average Yearly
Concentrations - uCi/cc®
             Tc-99
             U-234
             U-235
             U-238
             Alpha activity
             Beta activity
             Gamma activity
        8.6E-11
        2.6E-11
        1.3E-12
        3.0E-11
        2.6E-12
        1.2E-12
        2.2E-15
(a)  Derived from the U.S. Department of Energy, Effluent Information System - computer run
    OUKK001050A of 8/9/90 and extracted from DOE/BNL 10/5/90 submittal. All values are
    rounded off and entered as exponential notation; i.e., 8.6E-11 means 8.6 x  10"11
(b)  Values shown represent  stack concentrations and not offsite airborne activity. Total air
    volume discharged through stack is 1.9E+7 m3 for 1988. Associated waste volume: solid
    waste, 160 cubic feet; liquid waste, 20,490 gallons.
   . 444). This incinerator is used to process low-level radioactive waste generated by various

facility operations and research activities.
The incinerator is not equipped with off-gas treatment or air monitoring systems.  Radionuclide
emissions are based on the radionuclide distributions and inventories
characterizing the waste. Daily and weekly airborne monitoring is performed at two sampling

locations situated near the facility's site boundary.


Airborne  effluent releases  for the years  1986 to 1988 are shown in Table  1-22.  Seventeen
radionuclides were reported released between 1986 and 1988. In 1988, only H-3, C-14, Cr-51,
Tc-99, Sn-113, 1-125, and 1-131 were reported by BNL. In general, H-3 (about 95 percent) and
Sn-113 (nearly 72 percent) are the most predominant radionuclides reported over the 3-year

span.
                                          1-48

-------
          Table 1-22.    Brookhaven National Laboratory low-level radioactive
                        waste emissions00
       Radionuclides
1986
Yearly Releases - Ci/y00
       1987
1988
H-3
C-14
P-32
S-35
Cr-51
Mn-54
Fe-55
Co-57
Fe-59
Tc-99
Tc-99m
Ru-103
Sn-113
Sn-117m
1-125
1-131
Tl-201
9.4E-02
7.7E-04
2.5E-04
5.7E-04
1.1E-04
l.OE-05
5.1E-03
2.1E-05
O.OE-OO
l.OE-04
2.0E-04
1.2E-05
2.0E-04
4.2E-05
5.2E-04
2.1E-05
2.1E-05
1.6E-O1
2.2E-04
9.0E-07
2.5E-03
1.5E-03
O.OE-OO
O.OE-OO
O.OE-OO
l.OE-06
4.2E-05
l.OE-05
O.OE-OO
2.8E-03
O.OE-OO
8.9E-05
1.7E-04
O.OE-OO
5.6E-05
3.0E-06
O.OE-OO
O.OE-OO
5.0E-07
O.OE-OO
O.OE-OO
O.OE-OO
O.OE-OO
5.0E-09
O.OE-OO
O.OE-OO
2.3E-04
O.OE-OO
2.0E-05
l.OE-05
O.OE-OO
(a)  Extracted  from the U.S. Department of Energy, Effluent Information System - EPA
     Effluent Analysis Report For Calendar Years 1986 to 1988, run date of 9/18/89.
(b)  All values are rounded off and entered as exponential notation; i.e., 7.7E-04 means 7.7xlQ-
Data characterizing monthly radionuclide emissions are shown in Table 1-23. Radionuclides and
radioactivity releases are given for the years 1987, 1988, and 1989.  This information reveals
that waste was incinerated during only a few months each year, i.e., 5 months in 1987, and 3
months in 1988 and 1989.  Some radionuclides are present in each burn while others are not.
For example, H-3, C-14, C-51, Sn-113, and radio-iodines are the most often cited nuclides. In
terms of radioactivity released on a monthly basis, H-3, P-32, S-35, Cr-51, Sn-113, and 1-125
are by far the most predominant.
                                         1-49

-------
      Table 1-23.  Brookhaven National Laboratory low-level radioactive waste monthly
                   incinerator emissions for 1987-1989®
Part I: 1987 Monthly Burns and Releases - mCi®

Radionuclides        May         June         July
August
December
H-3
014
P-32
S-35
Cr-51
Fe-59
Tc-99
Tc-99m
Sn-113
1-125
1-131
Part II:
1.6E+O1 »(c)
1.5E-O1 7.0E-02
__
5.0E-03
6.2E-02 5.0E-03 5.0E-03
l.OE-03
1.2E-02 2.0E-02
l.OE-02
l.OE-02
4.6E-02 3.0E-03 6.0E-03
1.6E-02 l.OE-05
1988 Monthly Burns and Releases - mCi00
Radionuclides February September
H-3
C-14
Cr-51
Sn-113
1-125
1-131
»(c) l.OE-03
3.0E-03
'
2.3E-O1
1.1E-02
l.OE-02
1.5E+O1 1.3E+02
—
9.0E-04
2.5E+OO
1.4E+OO 5.3E-02
. __
l.OE-02
__
2.8E-OO
1.2E-02 2.2E-02
5.0E-03 1.5E-01

November
5.5E+02
—
5.0E-04
—
8.0E-03

 (a)  Extracted  from the U.S. Department of Energy, Effluent Information System - EPA
     Effluent Analysis Report For Calendar Years 1986 to 1988, run date 9/18/89 and 10/4/90
     DOE/BNL Submittal.
 (b)  All values are rounded off and entered as exponential notation; i.e., 7.7E-04 means
     7.7x10^.
 (c)  Signifies that no data were reported for that month.
                                         1-50

-------
        Table 1-23.  Brookhaven National Laboratory low-level radioactive waste monthly
                     incinerator emissions for 1987-1989
-------
         Table 1-24.  Brookhaven National Laboratory low-level radioactive waste
                            incinerator stack concentrations00
Radionuclides
H-3
C-14
P-32
S-35
Cr-51
Mn-54
Fe-55
Co-57
Fe-59
Tc-99
Tc-99m
Ru-103
Sn-113
Sn-117m
1-125
1-131
 Tl-201
                                       Average Yearly Concentrations - uCi/cc®
                                      1986            1987        1988
l.OE-08
8.6E-11
2.8E-11
6.3E-11
1.2E-11
LIE- 12
5.7E-10
2.3E-12
O.OE-00
1.1E-11
2.2E-11
1.3E-12
2.2E-11
4.7E-12
5.8E-11
2.3E-12
2.3E-12
1.8E-08
2.4E-11
l.OE-13
2.8E-10
1.7E-10
O.OE-00
O.OE-00
O.OE-00
L1E-13
4.7E-12
1.1E-12
O.OE-00
3.1E-10
O.OE-00
9.9E-12
L9E-11
O.OE-00
6.2E-12
3.3E-13
O.OE-00
O.OE-00
5.6E-14
O.OE-00
O.OE-00
O.OE-00
O.OE-00
5.6E-16
O.OE-OO
O.OE-00
2.6E-11
O.OE.OO
2.2E-12
LIE- 12
O.OE-00
 (a)  Derived from the U.S. Department of Energy, Effluent Information System - computer run
      CBLIR72445A,  8/9/90.                                            . .     m   .  .     ,
 (b)  Values shown represent stack concentrations and not offsite airborne activity.  Total air volume
      discharged through stack is 9.0E+6 m3 for each reported year.  All values are rounded off and
      entered as exponential notation; i.e., l.OE-08 means l.Oxia8.
  treatment system.  The off-gas treatment system consists of a baghouse, pre-filter, and single bank of

  HEPA filters. The stack servicing the heat-exchanger is not equipped with an off-gas treatment system

  since this exhaust stream does not mix with combustion gases.


  Stack releases are continuously monitored by an airborne radiation monitoring system. The sample is

  pulled through  a  particulate filter. Each filter is changed weekly and is  analyzed monthly, as a

  composite sample. Analytical procedures include the determination of gross alpha and gross beta
                                              1-52

-------
 include primarily Tc-99, U234, U-235, and U-238.  Tc-99 makes up about 60 percent of the total
 radioactivity released, and uranium, except for U-235, makes up 20 activity and the identification of
 specific radionuclides. The results of these analyses are reported and compiled monthly and yearly by
 INEL.
 Incinerator emissions are shown in Table 1-25. Airborne emissions typically include Co-60, Cs-137,
 Sr-90, Mo-99, and Mn-54.  Cesium and strontium are the major radionuclides routinely released; they
 comprise about 70 percent of the total radioactivity.  A review of the data indicates that mixed fission
 products  (gross beta) and mixed alpha products (gross alpha) are the most predominant sources of
 radioactivity.  On average, the WERF incinerator releases about 1,400 uCi of total radioactivity per
 year, based on 1987 INEL data (INEL88a,b).  Total activity,  shown as gross alpha and gross beta, and
 Sr-90 have been given for each of the four reported years.  All other nuclides are present  at much lower
 concentrations.  It can be noted that emissions have fluctuated over the four reported  years.  These
 concentrations represent airborne radioactivity at the point  of release and not at distant downwind
 locations.

       Table 1-25. Idaho Engineering Laboratory WERF incinerator emissions00
Radionuclides
Gross alpha
Gross beta
Sr-90
Cs-137
Yearly Stack Releases - Ci/yr®
1986 1987 1988
6.9E-09
1.3E-07
1.3E-07
»-(c)
3.3E-09
3.2E-08
7.9E-07
2.0E-07
7.9E-08
1.1E-06
1.4E-06

1989
5.7E-08
1.1E-06
9.4E-08

 ^ '         	J	7 —.,——. ^^M,U^.VM.W. v v » » uubw J-TJ.uaAU^ Will WAIL .L11J. \_UAlidUAJiI VJ YOlC-Ill. J.Z7QO UCtUl Ul J ]
     18, 1990,  and DOE/INEL submittal dated 10/5/90.
(b)   All values are rounded off and entered as exponential notation; i.e., 6.9E-09 means 6.9xia9.
(c)   Signifies that no data were reported.
Waste volumes and radionuclide concentrations are shown in Tables 1-26 and 1-27.  Although
several radionuclides are listed, waste activity is dominated by unidentified alpha emitters and
mixed fission products.  The waste volume processed yearly varied over a narrow range of

                                          1-53

-------
Table 1-26.   Idaho Engineering Laboratory WERF incinerator monthly
             emissions and processed waste volumes*1
Parti: 1987 Waste Volume and Activity Releases
Volume Activity Released - Ci0*
Month
Jan.
Feb.
Mar.
Apr.
May
Jun.
Jul.
AUE.
4 AW^«
Sept.
Oct.
Nov.
Dec.
Part II: 1988

Month
Jan.
Feb.
Mar.
Apr.
r
May
J
Jun.
Jul.
Aug.
Sept.
Oct.
Nov.
Dec.
(Cu. meters)
— to
279
_-.
210
304
118
122
218

127
100
—
Waste


























Volume and
Volume
(Cu. meters)
241
249
116
127
240
137
118
99
247
118
133
172
Cs-137 Sr-90 Gross Alpha Gross Beta-
5.6E-08 3.2E-09
1.6E-08 6.1E-09
1.1E-09 4.2E-09
1.6E-07 5.6E-09
8.9E-08 2.9E-09
5.0E-08 1.6E-07 7.9E-09
l.OE-07 6.4E-08 6.6E-09
2.4E-08 4.2E-09
5.0E-08 l.OE-07 5.9E-09
2.9E-08 7.2E-09
8.8E-08 3.9E-09
7.8E-09
Activity Releases
Activity Released
Sr-90 Gross Alpha
1.6E-07 l.OE-08
1.2E-07 1.9E-OB
2.9E-08 5.9E-1O
2.9E-08 1.3E-09
2.4E-08 5.5E-09
2.6E-12
6.7E-08 7.9E-09
9.9E-07 5.8E-09
3.8E-09 5.5E-09
1.3E-08 9.3E-09
1.4E-08 5.8E-09
7.3E-09
4.0E-08
3.4E-08
2.3E-08
3.5E-08
4.0E-08
9.8E-08
7.9E-08
5.6E-08
1.2E-07
7.8E-08
4.5E-08
4.8E-08

-Ci
Gross Beta
9.9E-08
2.0E-07
8.6E-09
1.6E-08
6.8E-08
5.4E-08
l.OE-07
6.0E-08
9.0E-08
1.3E-07
6.8E-08
1.8E-07
                                   1-54

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       Table 1-26.   Idaho Engineering Laboratory WERF incinerator monthly emissions and
                    processed waste volumes^, (Continued)
Part III: 1989 Waste Volume and Activity Releases
Month
Jan.
Feb.
Mar.
Apr.
May
Jun.
Jul.
Aug.
Sept.
Oct.
Nov.
Dec.
Volume
(Cu. meters)
__
5
—
251
244
119
1 10
230
239
—
209
217
Sr-90
1.9E-08
3.8E-08
3.3E-09
—
3.9E-1O
1.8E-10
.—
~
1.4E-08
—
2.0E-08
—
Activity
Gross Alpha
2.7E-09
1.4E-08
6.1E-09
__ .
3.5E-09
1.8E-09
3.6E-09 ;
5.0E-09
4.3E-09
8.5E-09
—
7.2E-09
Released - Ci
Gross Beta
5.7E-08
2.3E-07
4.3E-08
6.0E-08
6.7E-08
2.4E-08
1.5E-07
9.3E-08
5.9E-08
6.2E^08
1.8E-07
1.1E-07
     Obtained from DOE/INEL, submittal dated 10/5/90.
     All values are  rounded off and entered as exponential notation; i.e., 5.6E-08  means
     5.6x10-*.
     Signifies that no data were reported.
       Table 1-27.   Idaho Engineering Laboratory WERF incinerator low-level radioactive
                    waste radionuclide concentrations^
Radionuclides
                             1986
Average Waste Concentrations -
             1987
1988
Co-60
Nb-95
Zr-95
Cs-134
Cs-137
Ce-144
Beta/Gamma
Mixed Fission Products
Mixed Alpha Emitters
3.3E-07
2.7E-07
1.4E-07
2.9E-07
1.2E-06
1.9E-07
1.2E-07
1.1E-03
2.9E-04
1.3E-04
O.OE-OO
O.OE-OO
O.OE-OO
O.OE-OO
O.OE-OO
O.OE-OO
l.OE-03
2.3E-05
3.9E-06
O.OE-OO
1.5E-07
2.5E-08
1.8E-07
8.2E-09
O.OE-OO
7.7E-04
2.9E-05
(a)
Derived from the U.S. Department of Energy, Effluent Information
System - computer run IIAWR76055A, 8/9/90.
Total waste volume processed in each year is 1,611, 1,564, and 1,465 m3
for 1986, 1987, and 1988,  respectively.  All values are rounded off and entered  as
exponential notation; i.e., 3.3E-07 means 3.3xlO'7-

                                    1-55

-------
1,465 to 1,624 entered as exponential notation; i.e., 3.3E-07 means 3.3xlO'7. cubic meters, and
averaged about 1,570 m3. On a monthly basis, the processed waste volumes vary from about
5 to 250 cubic meters, averaging about 130 cubic meters per month over the four reported years.
Using the information given in Tables 1-27 and 1-28, the overall incinerator decontamination
factor (DF) has been estimated for mixed fission and alpha products, see Table 1-29.  The DF
is expressed as the ratio of the amount  of radioactivity introduced into the incinerator to the
amount that is observed on the discharge side of the offgas treatment system. The DF represents
the overall effectiveness of the incinerator in retaining radioactivity in ashes and within off-gas
treatment systems. A review of Table 1-29 indicates that DFs on the order of 1O+1° to  10+11
are routinely attainable.   These results  are generally  better than those experienced at  other
facilities.  A survey conducted by the IAEA reported DFs ranging from as low as 10 to as high
as 10+7 see subsection 1.3.1 for details (IAEA89).

INEL is in the process of finalizing the installation of a new incinerator facility, known as the
PREPP. The incinerator is located within INEL's TAN/TSF area. The PREPP incinerator is
currently not processing any radioactive waste.  Accordingly, there are no reported releases for
this facility.

The PREPP incinerator may eventually process transuranic waste, primarily including Pu-239,
Pu-240, Pu-241, and Pu-242, Am-241, Cm-241, and U-233. The process is designed to convert
TRU and hazardous waste in a form compatible for eventual disposal at the WIPP facility,
located in Carlsbad,  New Mexico.
 1.4.1.6 Savannah River Site Beta-Gamma Incinerator.  The Savannah River Site Beta-Gamma
 Incinerator (BGI) has been used to process solid low-level radioactive waste generated by various
 plant operations and to treat liquid waste, such as spent Purex solvents. The incinerator, located
 in Building 230H, has been intermittently operated over the past few years and has not been
 running since 1989.  The BGI will be replaced by the Consolidated Incineration Facility, which
 is scheduled to become operational in 1993.  This facility will process hazardous and mixed
 waste in addition to low-level radioactive waste.
                                          1-56

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             Table 1-28.  Idaho Engineering Laboratory WERF incinerator
                          stack concentrations00
Radionuclides
1986
Average Yearly Concentrations -
1987         1988         1989
Gross alpha
Gross beta
Sr-90
Cs-137
4.2E-16
8.1E-15
7.7E-15
-(c)
5.5E-16
5.4E-15
1.1E-14
2.8E-15
8.8E-16
1.2E-14
1.6E-14
—
3.7E-16
7.3E-15
6.0E-16
—
(a)  Derived from the U.S. Department of Energy, Effluent Information
     System - computer run HAWR76055A of 8/9/90, and DOE/INEL submittal
     dated 10/5/90.
(b)  Values shown represent stack concentrations and not offsite airborne
     activity. Total air volume discharged through stack is 1.7E+7, 6.0E+6,
     8.9E+7, and 1.6E+8 m3 for 1986, 1987, 1988, and 1989, respectively. All
     values are rounded off; entered as exponential notation; ie., 4.2E-16
     means 4.2xlO"16.
(c)  Signifies that no data were reported.
             Table 1-29.   Idaho  Engineering  Laboratory  WERF   incinerator  overall
                          decontamination factor''0
                                       Ratio of Waste to Stack Concentrations0"5
                          Waste/Air Ratio     Waste/Air Ratio     Waste/Air Ratio
Nuclides
Gross
alpha:
Gross beta
&MFP:
1986
10+u

10+1°

1987
10+io

10+n

1988
10+1°

10+io

(a)  Derived from the previous two tables, see text for details.
(b)  Values shown represent the ratio of waste activity to its corresponding stack concentration.
    All values are rounded off and entered as exponential notation; i.e., 10+" means about
    1.0xlO+u.
                                        1-57

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Airborne effluents from the BGI were treated by an off-gas system before being released. The
treatment system was equipped with a dry quencher (air-atomized) to cool combustion gases, a
baghouse, and a set of HEP A filters. Off-gases were released via a 60-foot stack with an exhaust
flow rate of 10,000 cubic feet per minute.

The stack effluent radiological monitoring system was comprised of a continuous sampling pump
and particulate filter system. Particulate filters were periodically removed and analyzed for gross
beta and gamma activity. Such filters were also subjected to gamma spectroscopy analyses to
identify specific nuclides.

Table 1-30 presents a summary of gaseous effluent releases for 1986, 1987, and 1988.  Tritium
is reported as the primary radionuclide for the three given years. Other radionuclides have also
been reported, but at much lower activity levels. Such radionuclides include: Ru-106,1-131, Cs-
134, Cs-137,  Ce-144, Am-241, Am-243,  Cm-242,  Cm-244, and unidentified beta/gamma
emitters. Together these radionuclides comprise about l.OE-5 Curies in 1986, <4.0E-5 Curies
in 1987, and 
-------
 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

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           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

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      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

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             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

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 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

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            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

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 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

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            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

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 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

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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

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 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

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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

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 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;
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      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

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                    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

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                                                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

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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

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                                                 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

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                                                 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

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                                                    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

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                                                    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
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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
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 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
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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
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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
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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
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 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
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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

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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

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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

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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

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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

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                                  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

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                      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

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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

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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

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                                                              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

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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

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                                            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

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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
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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
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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.
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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.
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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

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      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),
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            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.
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      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.
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 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-
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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
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 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

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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
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  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.
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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

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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

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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

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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

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                               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

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 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

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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

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        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

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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

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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

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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

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       "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

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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

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 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

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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

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       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

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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

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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

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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

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       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

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                                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

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          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

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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

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  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

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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

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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

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                  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

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                              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

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                                  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

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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

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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
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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

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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

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              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

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 •    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

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           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

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            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

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       •   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

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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

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                                     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

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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

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                                      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

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Temperature and pressure drop are important variables for the HEPA filters and the carbon
adsorption beds.  These are usually monitored.
                                          A 4-8

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                                     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

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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

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 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

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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

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                                       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

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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

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 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

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                                    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

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                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

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                 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

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                      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

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                                 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

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                              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

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                                               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

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                                             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

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                                       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

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                                             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

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                                   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

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