-  2nd Draft -
CONSIDERATIONS IN DEVELOPING AND USING
    METHODS FOR  ESTIMATING  DIFFUSE
      OR FUGITIVE AIR EMISSIONS
  OF RADIONUCLIDES AT DOE FACILITIES
              Prepared by
       S. Cohen  & Associates,  Inc.
         1355 Beverly  Drive
             Suite  250
       McLean,  Virginia  22101

     Under  Contract No.  68D20185
         Work Assignment 2-09
             Prepared  for
 U.S.  ENVIRONMENTAL  PROTECTION AGENCY
  Office  of Radiation  and  Indoor Air
           Washington,  DC
             Albert  Colli
       Work Assignment Manager
              July  1994

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Dear Rad NESHAPs folks,

     This document is a revision of a document we previously sent
to you, "METHODS FOR ESTIMATIONG DIFFUSE OR FUGITIVE AIR
EMISSIONS OF RADIONUCLIDES AT DOE FACILITIES," dated Oct, 1992.
Part of the reason for the revisions was to answer the comments
made by the DOE in their letter from Raymond Pelletier to William
Gunter, dated Dec 30, 1993.

     The following is a summary of the major changes:
Executive Summary--added
Chapt 2 - -added
Chapt 3--expanded to include DOE work; table 3-1 added.
Chapt 4--some new material
Chapt 5--5.1.2; 5.3.3, .4, & .5--added
Chapt 6 - -new
Chapt 7- - reworked

     NOTE THAT THERE ARE NO CHANGES TO THE ATTACHMENTS.
THEREFORE, I AM SENDING THIS BY POSTMAN TO REDUCE THE PAPER
BURDEN.  YOU CAN PRINT OUT A COPY THERE IP YOU WISH.

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                        TABLE OF CONTENTS

                                                          page

    EXECUTIVE SUMMARY                                     ES-1

1.  INTRODUCTION                                           1

     1.1  Background and Objectives                        1
     1.2  Evaluation of Methodologies                      2

          1.2.1  Methods for estimating fugitive
                 emissions of air pollutants               2
          1.2.2  Structure of report                       2

2.  IDENTIFICATION AND CHARACTERIZATION OF
    EMISSION SOURCES                                       3

     2.1  Types of Emission Sources                        4
     2.2  Types of Radiological Emissions                  5
     2.3  Characterization of Emission Sources             8

3.  RESUSPENSION OF PARTICULATES                          10

     3.1  Measures of Resuspension                        10
     3.2  Research on Resuspension                        12
     3.3  Studies of Wind Erosion                         14

          3.3.1  Mechanisms of wind erosion               14
          3.3.2  Characterizing wind erosion studies
                 prior to 1984                            15
          3.3.3  DOA Wind Erosion Equation                16

4.  EPA-ADOPTED PARTICULATE EMISSION MODELS               17

     4.1  Natural Occurrence:  Wind Erosion               17

          4.1.1  Open Areas                               17
          4.1.2  Open waste and storage piles (except
                 uranium ore and mill tailings)            19
          4.1.3  Uranium ore and mill tailings            20
          4.1.4  EPA Soil Screening Guidance              20

     4.2  Soil and Material Handling                      21

          4.2.1  Soil removal and haulage                 22
          4.2.2  Grading and shaping of soil              22
          4.2.3  Agricultural tillage and seeding         22
          4.2.4  Building demolition and material
                 disposal                                 22

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                    TABLE OF CONTENTS,  Cont'd

                                                         page

     4.3  Non-intrusive Action                            23

          4.3.1  Vehicular traffic on unpaved roads       23

     4.4  Control Methods                                 24

5.  MECHANISMS OTHER THAN RESUSPENSION                    25

     5.1  Evaporation From Ponds and Lagoons              25

          5.1.1  Evaporation models                       25
          5.1.2  Wet-Cooling Towers                       27

     5.2  Evaporation from contaminated soil              28

          5.2.1  Saturated soil                           28
          5.2.2  Subsurface contamination                 30

     5.3  Gaseous and Other Types of Emissions            31

          5.3.1  Re-entry drilling                        31
          5.3.2  Ground seepage of noble gases            31
          5.3.3  Emissions from buildings                 32
          5.3.4  Emissions from tank venting              33
          5.3.5  Emissions from equipment                 34

6.0  GUIDANCE ON ENVIRONMENTAL MONITORING PROGRAMS
     TO DEMONSTRATE COMPLIANCE WITH THE DOE NESHAPS       35

     6.1  Summary of NESHAPS Requirements                 35
     6.2  Sampling and Analytical Methodology             35

          6.2.1  Radionuclide as particulates             37
          6.2.2  Radionuclide as gases                    37

     6.3  Criteria for Environmental Monitoring
          Programs                                        38

          6.3.1  Measurements made at critical
                 receptor locations                       38
          6.3.2  Continuous sampling at the point of
                 measurements                             39
          6.3.3  Sampling and measurements of major
                 radionuclide contributor                 39
          6.3.4  Radionuclide concentrations causing
                 an effective dose equivalent of
                 1 mrem/yr must be readily detectable
                 and distinguishable from background      40

                                ii

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                    TABLE OF CONTENTS, Cont'd

                                                         page

          6.3.5  Radionuclide concentrations that would
                 cause an effective dose equivalent of
                 1 mrem/yr must be readily
                 distinguishable from background          41

     6.4  Quality Assurance Program in Response to the
          Performance Requirements of Appendix B,
          Method 114, 40 CFR 61                           43

7.  RECOMMENDED METHODS FOR ESTIMATING FUGITIVE AIR
    EMISSIONS OF RADIONUCLIDES                            45

     7.1  Estimation of Radionuclide Emissions Using
          Fugitive Dust Emission Models                   45

     7.2  Calculating Effluent Releases From Sampling
          Data                                            46

          7.2.1  Calculation of gaseous releases at NTS   46
          7.2.2  Critique of methods used at other DOE
                 sites                                    47
          7.2.3  Estimating fugitive particulate
                 emissions from environmental sampling
                 and monitoring                           48

     7.3  Summary of Recommended Methods                  49

8.  REFERENCES                                            52

9.  BIBLIOGRAPHY                                          58

Attachment 1  Excerpts from Control of Open Fugitive
              Dust Sources

Attachment 2  Excerpts from Compilation of Air Pollutant
              Emission Factors

Attachment 3  Excerpts from Hazardous Waste TSDF (Treatment,
              Storage, and Disposal Facilities): Fugitive
              Particulate Matter Air Emissions Guidance
              Document

Attachment 4  Excerpts from National Agronomy Manual

Attachment 5  Excerpts from NUREG-0570

Attachment 6  Excerpts from Superfund Exposure Assessment
              Manual

                               iii

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                          List  of tables

                                                         Page


Table 1-1  Radionuclide Classification and Radioactivity
           Distribution Using DOE Categories               6

Table 1-2  Radioactive Releases from DOE Diffuse Sources
           - 1992                                          7

Table 3-1  Reported Resuspension Factors                  13

Table 3-2  Wind Erosion Mechanisms vs Particle Size       14

Table 4-1  Summary of AP-42 Emissions Control Measures    24

Table 6-1  Physical Parameters of Selected Primary
           Radionuclides                                  36

Table 6-2  Examples of Backgrounds and Sensitivities of
           Some Principal Airborne Radionuclides Released
           from DOE Facilities                            42

Table 7-1  Summary of Methods for Estimating Fugitive
           Emissions                                      50
                                IV

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                        EXECUTIVE SUMMARY

ES.l  Background and Objectives

The Environmental Protection Agency (EPA) has promulgated in 1989
a national emission standards for radionuclides (codified  in 40 CFR
61,  National Emission  Standards for  Hazardous Air  Pollutants;
Radionuclides).   Subpart  H to  Part  61  addresses emissions  of
radionuclides from Department of Energy (DOE) facilities.

Emissions  from  DOE facilities  include those from  point sources
(i.e.,  stacks  or  vents),  and  those  from  diffuse or  fugitive
sources.    Subpart  H  provides  guidance  on  monitoring,   test
procedures  and  calculation of  effective  dose equivalents  for
emissions from point sources. However, Subpart H does not provide
any guidance  for radionuclide  emissions  from diffuse or fugitive
sources.   At present,  DOE sites  address  diffuse or  fugitive
emissions on a site-specific basis.   The purpose of this study is
to provide initial  technical assistance to EPA regional offices in
identifying generic methods for estimating annual air emissions of
radionuclides from diffuse or fugitive sources.

It  should be  noted that  because  of  various  activities,  it  is
difficult to identify a comprehensive  set  of methods applicable to
assess  a  broad range  of  conditions found  at  DOE  sites.   It  is
necessary  to identify  the unique  conditions  of  each  case  and
identify or develop the methodology  that  best suits each case. The
use of  default  values  should be carefully considered as they may
not be appropriate  for  the site or conditions being evaluated. This
aspect  is especially  important if multiple default  values  are
assumed  for  several  of  the  model  parameters, since  they  may
introduce, in the aggregate, an unrealistic degree of conservatism.

ES.2  Evaluation of Methodologies

The  literature  on  fugitive  or  diffuse  airborne  radioactive
emissions provides  limited  information on methods  for estimating
offsite releases.  For the sake of simplicity, the term "fugitive
emissions" is used  here to denote  fugitive  or diffuse emissions.
An  exception   is   the methodology  developed  for  calculating
particulate releases from uranium ore pads and mill tailings piles,
issued by the Nuclear Regulatory Commission.

By  contrast,  fugitive  emissions of  air pollutants  (other than
radioactivity) have been extensively studied, notably by the EPA.
EPA guidance documents recommend methods  for estimating many types
of fugitive emissions from hazardous waste treatment, storage and
disposal  facilities, and  from  other sources.  Since resuspension
models  for  windblown  dust  do  not  distinguish  the  type  of
contamination carried by particulates,  the same methodologies used
for  estimating  the releases  from hazardous  waste sites may  be
applied to releases from areas contaminated by radioactivity.

                               ES-1

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ES.3  Types of Emission Sources

In  the  context of this  report,  fugitive emissions  include  both
point and diffuse sources.   For example, point sources may include
stacks, vents, buildings,  releases  from discrete equipment, vented
tanks,  wet-cooling towers,  etc.   On  the  other hand,  diffuse
emissions originate from large area  sources,  e.g.,  spills,  waste
piles, salvage yards,  large areas of contaminated soil, etc.

The mechanisms resulting in the generation of airborne contaminants
are also  expected to vary.   The amounts or  emission  rates  will
fluctuate depending upon whether the mechanisms are man-made (e.g.,
surface grading  or drilling), or  natural in origin  (e.g.,  wind
erosion).  Some mechanisms may involve dynamic processes which may
also  result  in  varying  emission  rates.  Dynamic processes  may
include  such  effects  as  biotic activity,  growth of  vegetative
covers, migration of contaminants to greater soils depths, etc.

Emission rates can vary and be continuous or intermittent, as well.
Some  types  of releases may  be mitigated by  man-made  or natural
processes.  For  example,  the demolition of a building may first
require that  the facility be  decontaminated, which  would remove
some  of  the contaminants,  thereby reducing the  total  amounts of
radioactivity  which  might  be released.   Natural processes  may
include the migration of contaminants to greater soil depths due to
surface water infiltration. As a result,  surface soil contamination
levels would  decrease,  yielding lower emissions  rates from wind
resuspension.

ES.4  Types of Radiological Emissions

Since  DOE facilities  conduct a broad  range of  activities,  the
levels of radioactivity and radionuclide distribution may also vary
significantly.     The  physical   and   chemical  forms   of   the
radioactivity are also dependent upon the process being conducted.
Materials  may be  released  as particulates,  gases,   or  vapors.
Particulates  may be  associated with  radioactivity attached or
incorporated in resuspended soil  grains.   Gases may originate from
the venting of  tanks  or emanations  from waste  disposal sites.
Vapors  may  be released  by plant  processes  or  decomposition or
degradation of materials.
                               ES-2

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 ES.5  Characterization of Emission Sources              f?(<_/v-

 In  characterizing  emissions, the information  may  come ^ several
 sources.  For example, the contaminants may have been characterized
 as part of earlier field studies.  In this  case,  the  information
 may present  results  obtained by  direct  measurements and  sample
 analysis.     However,  this  information   would  only  present  a
 characterization at  a  specific  time,  without the  benefit  of
 assessing temporal  changes and dynamic  conditions.

 In other cases, the  data  may be generated during the conduct of
 routine environmental surveillance activities during which samples
 are periodically collected and analyzed.   Depending upon the scope
 of the environmental  surveillance program,  the data may  provide
 some information about  the distribution   of the  radioactivity in
 multiple environmental  media, provide  the means to identify and
 characterize  environmental   transport  mechanisms,  and   reveal
 contamination profiles as a function of time and location.

 ES.6  Resuspension  Processes and Other  Release Mechanisms

 Resuspension is the process of introducing particulate matter into
 the atmosphere that were once deposited on the ground from a plume
 or  cloud.    On the  other  hand,  suspension  is  the  process  of
 atmospheric entrainment of particles present on the ground from
 other events or sources.   In both cases,  the  entrainment  process
 takes place by the same mechanisms.   Three processes  have been
 identified, saltation,  suspension, and surface  creep.  ^Saltation
jrefers to  the  movement of  particles which  jump or bounce  a few
 inches above the surface.   These particles are  ejected from the
 soil surface,  fly  a short distance and  then fall back down.   Upon
 impact,   they  are  likely  to bounce  and  also  dislodge  other
 particles,  which may saltate, creep, or become suspended,  depending
 on the  size of the  target particle.  Suspension refers to the
 atmospheric entrainment of relatively smaller particles,  which can
 remain in the atmosphere and be carried over large distances.  It
 is believed  that  wind-induced suspension is  caused entirely by
 saltating particles.  Creep refers to the sliding or rolling motion
 of particles that are too  heavy to leave the ground but are pushed
 by the wind and the impact of smaller particles.

 A review  of the  literature  indicates that  it is difficult to
 predict  resuspension  factors with  any  accuracy.    Typically,
 mechanically-induced  resuspension  factors vary over eight orders of
 magnitude,   from 10"10  to 10"2  m"1.   For wind-caused  resuspension
 factors vary over  seven orders of magnitude, 10"10 to 10"3 m"1.  The
 major  factors  known  to  have a  direct   impact on  resuspension
 mechanisms  include  weathering and physical  and chemical properties,
 including  particle chemical  composition,  solubility,  size  and
 shape, density, moisture contents, erodible fraction, and threshold
 velocity.   Weathering and migration to greater  soil depths have the
 tendency to reduce  resuspension factors.

                               ES-3

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Test have also shown that it is not uncommon to have resuspension
factors decrease by 2  to  3  orders of magnitude over a relatively
short time, e.g., several days.

Other release mechanisms include water evaporation from ponds and
lagoons.    Evaporation is  governed  by  air  temperature,  vapor
pressure,  dew  point,  wind  speed,  and  insolation.    Complex
relationships have been developed to estimate the evaporation rates
for lakes and the so-called "pan" evaporation rates.  Evaporation
or volatilization also could be a  significant release mechanism of
radioactivity from moisture saturated soils.

Another types of unique releases include the release of noble gases
from  the Nevada  Test Site.    These releases  occur during  the
re-entry  drilling of  cavities  left after underground  nuclear
detonations.  In ground  seepage,  noble gases  emanate out of the
soil and rocks via fissures and cracks caused by the detonation.

Emissions may also occur  from  buildings through vents,  stacks or
through  natural  ventilation.   The  mechanisms  leading  to  such
releases may be  induced mechanically (e.g., exhaust fans)  or via
natural means (e.g.,  convection and stack  effect).  Other releases
may be associated with  the operation of specific types of equipment
(e.g., compactors,  cooling towers) and venting of process equipment
(e.g., tanks).

ES.7  EPA-Adopted Emission Models

Over  the  past   decade,  the  EPA  has  conducted   numerous  field
investigations to characterize particulate emissions from various
sources.  These  studies  have led to  the  development of emission
models for a number of sources.  Most recently, the EPA has issued
standardized guidance  to  support  the planning  of remedial action
activities  at NPL  sites.   One  of  the  documents  provides  the
methodology  for  deriving  particulate emission  factors.  Finally,
additional models are presented in documents addressing the control
of open fugitive dust  sources.   Many of the models are reproduced
in guidance documents targeting hazardous waste  sites and temporary
storage facilities.  A number of the models have been incorporated
into the Compilation of Air Pollution Emission Factors, AP-42, also
issued by the EPA.  Relevant excerpts from the cited documents are
described or attached  to this report.

It should be noted that all of the models are complex and require
extensive information  about specific parameters.  The models must
therefore be carefully evaluated to justify their use in specific
applications.  Many  models  also rely on  default parameters with
little  or  no information as  to  their  justification.    In some
instances,  site specific data may  not be readily available, unless
specific studies are launched to obtain such information.
                               ES-4

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Given that various sources of information may be available,  it is
important to identify,  screen, and use the most appropriate data in
characterizing the presence of contaminants.  In decreasing order
of desirability, possible sources of information include:

•    Emission data as measured at the source.

•    Results from specific site characterization studies.

•    Results from routine sampling and monitoring.

•    Process or activity related information.

•    Default data.

The use  of  environmental  monitoring stations  for demonstrating
compliance with the  NESHAPS  rule or for  the purpose  of deriving
release rates are similarly fraught with uncertainties.  However,
these approaches  must be  carefully evaluated  for  its technical
merits.    The development  of such  models requires that  complex
factors be considered, including, among others:

•    validation of the deployment strategy,  locations, and numbers
     of environmental sampling stations.

•    validation of the selected sampling and analytical methods for
     the expected radionuclides.

•    representativeness of the field data to the emission sources.

•    atmospheric behavior of contaminants while in transient from
     the source of emission to the sampling  station.

•    atmospheric dispersion and concurrent meteorological data for
     the site.

•    site  specific   features   (e.g.,   terrain,   ground   cover,
     obstructions, control measures to mitigate releases,  etc.).

•    radiological, physical,  and chemical characteristics of the
     contaminants.

     physical characteristics of emission sources  and temporal and
     spatial distributions of emission rates.
                               ES-5

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                            Chapter 1

                           INTRODUCTION

1.1  Background and Objectives

On December  15,  1989, the Environmental  Protection  Agency (EPA)
promulgated national emission standards for radionuclides (see 54
FR 51654 [EPA89b, c]), which are codified in 40 CFR 61, "National
Emission Standards  for  Hazardous  Air Pollutants;  Radionuclides".
Subpart H  to  Part 61 addresses emissions  of  radionuclides other
than   radon   from   Department  of   Energy   (DOE)   facilities.
Specifically, Subsection 61.92 states:

     "Emissions of radionuclides to the ambient air from Department
     of Energy facilities shall not exceed those amounts that would
     cause any  member of  the  public to  receive  in any  year an
     effective dose equivalent of 10 mrem/yr."

Emissions  from  DOE facilities  include  those  from  point sources
(i.e.,  stacks or vents),  and those  from  diffuse or  fugitive
sources.  A diffuse source is defined as an area source from which
emissions are continuously distributed over a given area or emanate
from  a number  of  points randomly  distributed over  the  area.
Examples of diffuse sources include resuspension of dust deposited
on open fields, evaporation from ponds, and ground seepage of gases
following underground nuclear tests.   A fugitive source is defined
as an undesigned  localized source, such  as a leaking seal during
fe-entry drilling following an underground nuclear test.   Subpart
H provides guidance on monitoring, test procedures and calculation
of effective  dose equivalents for emissions  from  point  sources.
Subpart H does not provide guidance for radionuclide emissions from
diffuse or fugitive sources.

At present, each  of the DOE sites addresses  diffuse or  fugitive
emissions on a site-specific basis.  The purpose of this study is
to  provide  technical  assistance to EPA regional  offices  in
identifying generic methods for estimating annual air emissions of
radionuclides from diffuse or fugitive sources.

It should  be  noted that  because of various activities,  it is
difficult to identify a  comprehensive set  of methods applicable to
assess  a  broad range of conditions  found at DOE  sites.   It is
necessary  to  identify  the unique  conditions of  each  case  and
identify or develop the methodology that best suits the conditions.
The use of default  values  should  be  carefully considered as they
may not be appropriate for the  site or conditions being evaluated.
This aspect is especially important if multiple default values are
assumed  for   several  of  the model  parameters,  since they  may
introduce, in the  aggregate, an unrealistic degree of conservatism.

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1.2  Evaluation of Methodologies

1.2.1  Methods for estimating fugitive emissions of air
       pollutants

The  literature  on  fugitive or diffuse  airborne  radionuclide
emissions  contains a  limited number  of  methods  for  estimating
off-site releases  during  normal  operations.   (The term "fugitive
emissions" will be used to denote fugitive or diffuse emissions.
A notable  exception  is the methodology developed for calculating
particulate releases from uranium ore pads  and mill tailings piles
which is described in Regulatory  Guide  3.59 (NRC87), issued by the
U.S. Nuclear Regulatory Commission (NRC).

By contrast,  fugitive emissions of hazardous air pollutants (other
than radioactivity) have been extensively studied, notably by the
EPA and its contractors.   EPA guidance documents recommend methods
for estimating  many types  of fugitive emissions  from hazardous
waste treatment,  storage and disposal facilities (TSDF), as well as
other  sources of  air  pollutants.    Since  the  models  for  the
resuspension of windblown  dust,  for  instance,  do not distinguish
the  type  of  contamination  carried   by   the  dust,   the  same
methodologies used for estimating the releases from hazardous waste
sites  can be  applied  to  releases  from  areas  contaminated  by
radionuclides.

1.2.2  Structure of report

In this  report,  fugitive  emissions are grouped  into  two general
categories: resuspension of particulates, and emissions of gases or
vapors.

•    Chapter  2  presents  a  general  descriptions  and  discussions
     about various types of fugitive  and diffuse emission sources.
     Given the potentially broad range of conditions  and sites,
     this  chapter   addresses only   general  considerations  in
     identifying and characterizing such emission sources.

     Chapter  3  presents  a general  discussion  of resuspension,
     including  research  studies  aimed  at  understanding  this
     phenomenon as well as some early predictive models.

•    Chapter  4  describes  a  few  selected  models  for  estimating
     particulates  releases  along with  references to the relevant
     sources in the literature and any proposed improvements to the
     models.  Methods that are presented in EPA guidance documents
     are recommended when  they are applicable to emissions from DOE
     sites.   Relevant excerpts from  the  cited documents  are
     attached to this report.

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Chapter 5 addresses emissions of radioactive gases and vapors.
The recommended method  for  estimating  releases  of tritiated
water vapor  is  based on a water evaporation model  given in
NUREG-0570, an Nuclear Regulatory Commission document (NRC79) .
The document is  used to assess the hazards posed by accidental
releases  of  toxic  chemicals.  This chapter  also  presents
additional information from an OSWER directive, the Superfund
Exposure Assessment Manual (EPA88c). This document presents a
model for vapor emission from contaminated soil. This method
is recommended  for  estimating the evaporation  of tritiated
water from unsaturated soil.  Methods currently used by some
DOE sites  for estimating  the  emissions of radioactive gases
and vapors are described in this chapter.

Chapter  6   presents  a   summary  of   methods   and  general
considerations   in   using   environmental  monitoring   for
demonstrating compliance with the NESHAPS rule.

Chapter  7  presents  a  summary  of method and  alternative
procedures  for   estimating  the  various  types  of  releases
addressed in this report. They are grouped by mechanisms and
sources.

The  enclosed  six  attachments  contain  specific  sections
extracted  from  cited literature sources.  They  are included
here for additional  information  and facilitate the evaluation
of the selected methods.

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                            Chapter 2

     IDENTIFICATION AND CHARACTERIZATION OF EMISSION SOURCES

There  are potentially  numerous  types  of  diffuse and  fugitive
emission sources.  Given the potentially broad range of conditions
and sites, this  chapter addresses only  general  considerations in
identifying and characterizing emission sources.

2.1  Types of Emission Sources

In the  context of this report,  fugitive emissions  include both
point and diffuse sources.   For example, point sources may include
stacks,  vents,  buildings,  releases from  discrete processes  or
equipment, vented  tanks,  wet-cooling towers,  etc.  On  the other
hand,  diffuse emissions originate from  large  area sources, e.g.,
landfills, spills,  waste  piles,  salvage yards,  large  areas  of
contaminated soil, etc.

The mechanisms resulting in the generation of airborne contaminants
are also  expected  to vary.   The  amounts and  emission rates will
fluctuate depending upon whether the mechanisms are man-made  (e.g.,
surface  grading  or drilling), or natural  in origin  (e.g., wind
erosion).  Some mechanisms may involve dynamic processes which may
also  result   in  varying  emission rates.  Dynamic processes  may
include  such effects  as  biotic  activity  on  soils,  growth  of
vegetative covers,  migration  of  contaminants  to greater soils
depths, etc.

Regardless of the  types  of   sources,  emissions  could also  be
continuous or  intermittent in nature.   Continuous emissions may
include  gaseous  emanations from  landfills,  evapo-transpiration,
etc.  Intermittent  releases  may  be due   to   the  operation  of
equipment, building  exhausts, tank  vents,  etc.   In all  cases,
emissions rates and total amounts of  materials released could also
vary  when  compared   to  past or similar  operations  conducted
elsewhere on the site.

Some types of releases  may be mitigated by man-made  or natural
processes.   For  example, the demolition of a building  may first
require  that  the facility  be   decontaminated  in  response  to
administrative requirements.   The decontamination process would
remove some or all of the contaminants, thereby  reducing the total
amounts  of material  (and radioactivity)  which could be released.
Natural  processes  may  include the migration of  contaminants to
greater soil  depths due  to surface water infiltration. As a result,
surface  soil  contamination  levels would decrease, yielding lower
emissions rates from  wind resuspension.  However, should the deeper
soil layers be disturbed by mechanical  means,  the emission rates
might  potentially increase depending  upon the amounts of soil
exposed, size of area involved, and resuspension mechanisms.

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In terms of relative importance, releases from diffuse and fugitive
emissions  may  vary  depending  upon  other  types  of  on-going
activities.  For example,  for sites with operating facilities, the
amounts  of  radioactivity due  to  normal  plant  operations  may
dominate over that produced by diffuse and fugitive emissions.  For
sites undergoing remediation, the amounts of radioactivity released
by  remedial  activities  may  be  the  sole source  of  airborne
emissions.   Although  such emissions are  relatively  much smaller
than those emitted by normal operations, they would nevertheless be
considered in demonstrating compliance with Subpart H.

2.2  Types of Radiological Emissions

Since  DOE facilities conduct  a broad  range of activities,  the
levels of radioactivity and distribution of radionuclides may also
vary  significantly.    The physical  and  chemical  forms of  the
radioactivity  are also dependent  upon  the process  or  activity
causing the releases.  Materials may be released as particulates,
gases,   or  vapors.     Particulates   may   be   associated   with
radioactivity attached or  incorporated  in  resuspended soil grains.
Gases may  originate from  the venting of  tanks  or emanations from
landfills.    Vapors  may  be  released  by  plant  processes  or
decomposition or degradation of materials.

Given  the  diverse  range of  activities  taking  place  at  DOE
facilities, it is not possible to list all radionuclides that may
be  present in  fugitive  and  diffuse   emissions.   However,  such
radionuclides may include  H-3, Mn-54,  Co-60, Sr-90, Cs-134, Cs-137,
Ce-144,  Pu-239,  Pu-241,  U-238, Th-234,  Ra-226,  Rn-222,  depleted
uranium,   among   others.      Obviously,   this  listing   is  not
comprehensive, but is believed to be representative of some of the
major alpha,  beta,  and  gamma emitters contained in  DOE  waste or
present  at contaminated  sites. Table  2-1  presents  an  aggregate
distribution of radionuclides contained in waste classified by the
DOE (DOE92a).

Some  insight  about the amounts  of  radioactive emissions may be
obtained from the DOE's 1992 NESHAPS Summary Report  (DOE94).  Table
2-2  presents  a  summary  of  radionuclide  releases  from diffuse
sources  emitted  by production sites,  research  laboratories,  and
remedial  action,  storage, and disposal sites.   As  can  be noted,
most of  the  radioactivity is associated  with tritium (96.6%) and
noble gases  (3.1%).   The  balance of the  radioactivity  is due to
transuranics and others nuclides.  As a  category,  "Others" does not
include radon gases (Rn-220 or Rn-222).  The 1992 DOE report does
not provide emission data  for radon released for all cited sources.

This information  is presented  for  illustrative  purposes and does
not imply  that these radionuclides,  either singly  or in groups,
will always be present in airborne emissions, and if present, the
relative distribution need not follow that shown  in Tables 2-1 and
2-2.

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Table 2-1   Radionuclide Classification  and Radioactivity
               Distribution Using DOE  Categories**0
                  Fission        Activat.
     U/Th          Product        Product            Alpha         Other
Nuclide  Percent  Nuclide Percent  Nuctide  Percent  Nuclide  Percent Nuclide  Percent
Tl-208
Pb-212
Bi-212
Po-212
Po-216
Ra-224
Ra-228
Ac-228
Th-228
Th-231
Th-232
Th-234
Pa-234m
Pa- 234
U-23S
U-238




0.0017
0.0045
0.0045
0.0029
0.0045
0.0045
0.0269
0.0269
0.0045
0.0259
0.273
33.197
33.197
0.0034
0.0258
33.197
100



Co- 60
Sr-90
Y-90
Zr-95
Nb-95
Tc-99
Sb-125
Te-125m
Ru-106
Rh-106
Cs-134
Cs-137
Ba-137m
Ce-144
Pr-144
Pm-147
Sm-151
Eu-152
Eu-154
Eu-155
0.08
7.77
7.77
1.27
2.83
0.02
2.93
0.73
6.39
6.39
0.38
17.31
16.38
14.67
14.67
0.06
0.11
0.09
0.09
0.06
100
Cr-51 4.95
Mn-54 38.10
Co-58 55.40
Fe-59 0.49
Co-60 0.87
Zn-65 0.19
100












Pu-238
Pu-239
Pu-240
Pu-241
Am- 241
Cm- 242
Cm- 244












2.62
0.20
0.70
96.4
0.004
0.056
0.02
100











H-3
C-14
Mn-54
Co-58
Co-60
Sr-90
Y-90
Tc-99
Cs-134
Cs-137
Ba-137n
U-238







1.22
0.06
6.76
6.24
18.03
8.48
8.48
0.12
13.98
18.45
17.45
0,73
100







(a) Extracted from the 1992 Integrated Database,  Table C.5 (DOE92a>. Totals may not
   exactly add up to 100X due to rounding off. "Alpha" are for nuclides of <100 nCi/g.
   "Other" includes unknown radionuclide compositions or mixtures.

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Table 2-2  Radioactive Releases from DOE  Diffuse Sources - 1992(a)
                Production Sites and Research Laboratories(b)
               Tritium    Gases      TRU     Others     Total
Activity (Ci)  8.6E+03   2.8E+02   2.8E-03   1.6E+00   8.9E+03
Percent           96.6       3.1     <0.01      0.02       100
                Remedial Action, Storage, and Disposal Sites
               Tritium    Gases      TRU     Others     Total
Activity (Ci)    —        —         —     l.OE-04   l.OE-04
Percent                                          100       100
(a) Extracted from Table 4, DOE94.
(b) Radon releases include 4,234 Ci for Rn-220 and 23.4 Ci
    for Rn-222.
                                7

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2.3  Characterization of Emission Sources

In  characterizing emissions,  the information  may come  several
sources.  For example, the contaminants may have been characterized
as part of earlier field  studies.   In this  case,  the information
may present  results  obtained  by direct measurements  and  sample
analysis.    However,  this  information  would  only  present  a
characterization  at   a  specific time,  without  the  benefit  of
assessing temporal changes and dynamic conditions.

In other  cases,  the  data  may be generated  during the  conduct of
routine environmental surveillance activities during which samples
are periodically collected and analyzed,  e.g., when characterizing
radionuclides concentrations in water, soils, sediments, vegetation
samples.     Depending  upon   the  extent and   duration  of  the
environmental  surveillance  program,  the data  may provide  some
information about the distribution of the contaminants in multiple
environmental media,  provide  the means to identify  and characterize
environmental  transport  mechanisms,  and  reveal  contamination
profiles as a function of time and location.

The EPA has  issued  some  guidance  for  the characterization of
radioactivity   in contaminated  soils   (EPA92).   The  guidance
identifies requirements for  characterizing  the radiochemical and
petrographic  properties  of  soils.  The  guidance addresses  the
following major aspects:

•    Soil grain distribution as  a function  of weigh, particle
     size and shape,  and density.

•    Radioactivity and soil/contaminant relationship as a function
     of weigh, particle size and shape, and density.

•    Mineral and physical properties as a function of size
     fractions of the contaminants (e.g., contaminants) and host
     material (e.g.,  soils).

•    Soil/contaminant chemical properties as a function of weigh,
     particle size and shape, and density.

The EPA guidance uses a  multi-tiered  approach and  presents a flow-
chart with which  to  conduct  the characterization of contaminants
and soils.

Some types  of  releases  may be  characterized  by evaluating the
process resulting  in the  emissions.    For example,  the amount of
radioactivity could be determined from knowing the  concentration of
a  specific  radionuclides  and  applying  factors  representing the
distribution  of the  radioactivity between  specific phases  of a
process,  e.g.,   liquid  to  gas,  filtration efficiency,  release
fraction from waste treatment processes,  resuspension factor, etc.
Alternatively,  such  emissions  could be monitored  by  installing

                                 8

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sampling equipment and monitoring each release as it occurs.

Given that various sources of information may be available, it is
important  to  identify and  use  the  most  appropriate  data  in
characterizing the presence of contaminants.  In decreasing order
of desirability, possible sources of information include:

•    Emission data as measured at the source.

     Results from specific site characterization studies.

•    Results from routine sampling and monitoring.

•    Process or activity related information.

     Default data.

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                            Chapter 3

                   RESUSPENSION OF PARTICULATES

Resuspension is the process of re-injecting particulates into the
atmosphere  that  have  been  deposited  on the  ground  from  an
atmospheric  plume  or   cloud;   suspension  is   the  process  of
atmospheric entrainment of particles which have been deposited on
the ground  in  some other manner.  Since the  entrainment in both
cases takes place by the same mechanisms, the two terms are often
used interchangeably,  depending on the context.  Pollution studies
usually  refer  to resuspension while  discussions  of agricultural
soil losses use the term suspension.

3.1  Measures of Resuspension

Early  resuspension   studies   involved  measuring  the  airborne
concentrations of contaminants in particulate form at some height
above the ground and relating those concentrations to the putative
source term, i.e., the level of contamination on the ground.  The
result of this  analysis was a irersuspension farrhp'f].  the ratio of the
concentration in the air to that on the  ground:     .. /  ?
                                             c.      2/^    *  ^
     K = C + a                          L * -tl      -^7^3-1)

     K = Resuspension factor, m"1.
     C = Concentration in air, g/m3.
     a = Surface concentration, g/m2.

Resuspension factors  have been determined for  a wide  range of
natural  stresses  (i.e.,  wind erosion)  as  well  as  mechanical
stresses  due  to  human  activity.  Resuspension  factors due  to_
mechanical stresses vary over more than  eight orders of magnitude
while  those due  to  wind alone vary  over more than  six orders
(NIC88).  Such variation aside, a resuspension factor describes  a
static situation and is therefore useless in predicting an emission
rate.

A [j-qguspenslop  rata  is  the  ratio  of  the vertical  flux  of  a
contaminant to its surface concentration:
     R = * -5- a                           |<-- ^-           (3-2)

     R = Resuspension rate, s"1.
     * = Vertical flux, g/m2-s.
     a = Surface concentration, g/m2.

In principle,  if  R and a were known,  the emission rate could be
calculated. Since Eq.  (3-2) yields:

     * = R •  a,      ,                                     (3-3)
                                10

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and since the total emission rate is equal to the flux multiplied
             .
<
by the area:

     E = * • A = R •  a '  A         r* "* >                 (3-4)

     E = Emission rate, g/s.         £" X. ^ C ^  f~  «^~;
     A = Area of source,  m2 .

In reality, such a procedure is  encumbered with numerous problems.
Sehmel (DOE84, Ch. 12)  has  reported experimental determinations of
resuspension rates as a function of wind speed,  particle size and
surface  roughness.   Rate  measurements  are  reproducible  under
carefully  controlled  conditions.    However,  resuspension  rates
observed in  a single  field location varied over  four  orders of
magnitude,   while  other  reported rates  varied  over almost  six
orders .  Another problem is inherent in the  determination  of a.
'kddionuclide contamination of exposed soil often extends below the
surface,   especially   in   loose  or   disturbed   soil  where  the
contamination  has   "weathered   in"   and  may  be  exponentially
distributed.  The contamination  profile  may  then  be subject to
dynamic processes which may result in varying resuspension rates.
Dynamic processes may  include such effects  as biotic activity on
soils, growth of vegetative covers,  etc. The question then arises
as to the  depth of the  soil  layer  which should be  used  in this
calculation.   Since  different thicknesses of the  soil  layer can
become resuspended,  depending on such  factors  as the  degree of
compaction, moisture, resuspension mechanisms, and the duration and
speed of the wind, a is not a uniquely determined quantity.
                   \
This problem may  be  further complicated  by the  use of mitigating
measures to reduce the resuspension rate. In some instances it is
required to apply  an agent to reduce the amount of dust to limit
exposures  to workers or  meet environmental protection standards.
Water is most commonly used  for this purpose.  Accordingly,  the
application of water may result in a lower resuspension rate.

The methodology identified  earlier would then be redefined as:

     E = R • a • A                                       (3-5)
      /                                 .
     R = Mitigated resuspension rate, s  .

     Where the other terms  are as previously defined.

3.2  Research on Resuspension

Recent studies  on the resuspension  of  particulate radionuclides
include those by Langer (DOE86) , Nielsen et al. (NIE90) , Pettersson
and Koperski  (PET91) ,  and  Finder et al.  (PIN90) .   Guidance for
calculating  particulate  releases  from uranium  ore pads  mill
tailings piles has been issued by the  Nuclear Regulatory Commission
(NRC87) and is embodied in the computer model MILDOS-AREA (ORNL92) .

                                11

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Other resuspension studies include those of Reeks et al.  (REE88),
and  Nicholson  and  Branso   (NIC90).    The Fourth  International
Conference  on  Precipitation  Scavenging,  Dry  Deposition,  and
Resuspension, sponsored  by the Department of Energy (DOE), dealt
extensively  with  this  and  related subjects  (PRU83).   Earlier
research on resuspension has  been summarized by Sehmel  (DOE84, Ch.
12) .  Later updates  were conducted  by  Nicholson   (NIC88),   Pye
(PYE87), and the Nuclear Regulatory Commission (NRC92).

A  review  of the work sponsored  by the DOE indicates  that it  is
difficult to predict resuspension rates with any accuracy  (DOE84,
SEH80).  The work has shown that  mechanically-induced resuspension
rates vary over eight orders  of magnitude, from 10'1U  to 10'* m'1. For
wind-caused  resuspension,   rates   vary  over  seven  orders   of
magnitude,10"IU  to 10"-1  m1.    The  major factors known  to have  a
direct impact  on resuspension mechanisms  include  weathering and
physical  and chemical  properties,  including particle chemical
composition,  solubility,  size   and  shape,   density,  moisture
contents,  erodible fraction,  and  threshold velocity.  Table 3-1
presents a summary of resuspension factors.

Weathering and migration to  greater soil depths have the tendency
to  reduce  resuspension  factors.    The  reduction   is primarily
dependent upon the surface characteristics, weathering processes,
and mechanism causing resuspension. Test have shown  that it  is not
uncommon to have resuspension factors decrease by 2  to  3  orders  of
magnitude over  a  relatively  short time, e.g.,  typically after  30
days.  Resuspension factors  have been  developed to reflect this
aspect  (NRC83).    A model  developed  by  the  NRC  includes   an
exponential time  component  and  retains a minimal  value for the
resuspension  factor when the  exponential term  vanishes to zero
(NRC83).

The proposed expression  is:

     K(t)  = [10'9  -I-  10'5 • exp-(0.6769t) ]                (3-6)

     K(t)  = time dependent  resuspension factor, m"1.
     t     = time, year.

As can noted,  after about 15  years  the exponential term becomes
insignificant  and  the  resuspension  factor  effectively remains
constant thereafter at 10~9 m .

Other  expressions  have been  developed  which  include multiple
exponential components,  each with its  own constant for  specific
time intervals.
                                            o
                                12

                                              - (o
                                                       O

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Table 3-1  Reported Resuspension Factors
Condition
Resuspension factor
 range (m-l)(b)
Comments
Wind-caused
Mechanically-
 caused
                    2E-11 to 8E-09
                    9E-08 to 1E-07
                    9E-08 to 5E-07
                    1E-04 to 1E-09

                    9E-11 to 3E-04
                    2E-13 to 6E-10
                            <2E-09

                            <5E-10

                    4E-09 to 5E-08
                    2E-06 to 3E-04
                    IE-OS to 1E-02
                    1E-10 to 4E-02
                       Bare soil, Y-90
                       Po-210 oxide
                       U3°8
                       Pu in soil, time
                       dependent model
                       literature review
                       NTS, Pu aerosols
                       Test debris, 13 y
                       after deposition
                       Test debris, 22 y
                       after deposition
                       Cs-137, Chernobyl
                       Pu
                       ZnS, per event
                       literature review
(a)  Extracted from Table 6.4, NUREG/CR-5512  (NRC92).
(b)  Exponential notation, 2E-11 means  2.0  x  10"11.
                                13

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3.3  Studies of Wind Erosion

3.3.1  Mechanisms of wind erosion

Wind erosion of soil and other  finely divided materials is caused
by  three processes:   saltation, suspension,  and surface creep.
Saltation refers to the movement of particles which jump or bounce
a few  inches  above  the surface. These particles are ejected  from
the soil surface  at a  steep vertical angle, fly a  short distance
and  then fall  back down.    Particles  subject to  saltation are
generally between 0.1  and  0.5 mm in diameter.   Upon impact,  they
are likely to bounce and also dislodge other particles, which may
saltate, creep  or become  suspended, depending on the size of the
target particle.   The resulting avalanche  increases the rate of
erosion  as the cascade proceeds downwind.

Suspension refers to the atmospheric entrainment of particles  less
than  about  0.1  mm in  diameter.   Such particles  constitute an
aerosol which can remain in  the  atmosphere and be carried for large
distances.  It  is belj-eved  that Minri-inrhintsH g^gpgns-irm  ig r-aiig«a^
^ntirely by saltating  particles.  Creep refers to  the sliding or
"rolling "motion of particles greater than about  0.5 mm in diameter,
which are too heavy to leave the ground but are pushed  by the  wind
and  the  impact  of  smaller  particles.   These  mechanisms  are
summarized in Table 3-2, below.
Table 3-2  Wind Erosion Mechanisms vs  Particle  Size
          Mechanism:    Suspension      Saltation        Creep
 Particle Size  (mm):     <  0.1         0.1  -  0.5      0.5  -  1.0
                                14

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3.3.2  Characterizing wind erosion studies prior to 1984

Earlier  wind  erosion   studies   laid   the  groundwork  for  the
intensified efforts to develop methodologies to predict emissions
of wind-blown particulates during the past ten"years.  Smith et al.
(SMI82) reviewed but did not evaluate 15 models developed prior to
1982.    Smith  and  Whicker  (SMI83)   performed  a  quantitative
comparison of five models, using a hard-rock thorium ore stockpile
as a hypothetical source.  The models were judged on the basis of
availability of  required data and sensitivity to  critical  input
parameters.   No comparisons  of  model  predictions with measured
emissions were performed.  The combined  suspension model of Travis,
a version of which was incorporated into the NRC codes UDAD,  FGEIS
and  MILDOS,  as well  as  these three codes (treated as  a  single
model), were found to be the most suitable  ones for the particular
case studied.

Gillette  (GIL83a)  summarized determinations of  the  minimum wind
stresses, expressed as threshold friction velocities, necessary to
initiate wind erosion events in arid soils.   (Friction velocity is
an abstract concept used  to characterize  the vertical  wind  speed
profile  in the  lower  atmosphere.    A detailed explanation  is
presented by Randerson in DOE84,  Ch.  5).  Gillette concludes that
the  threshold  velocity  in  non-crusted soils  is related to  the
aggregate size distribution of particles on the soil surface.   He
also discusses  the behavior  of crusts on soil  surfaces  and  the
mechanisms by which such crusted soils become erodible.

Gillette  and  Cowherd  (GIL83b) discuss the role  of  resuspension
rates in  estimating  fugitive dust emission and  soil erosion  and
present a simple model based on this concept.  The model assumes a
simple  form when  applied to emissions  from  rapidly  depletable
sources such  as  dust deposited on paved  roads or piles  of coal
dust.  In determining  long-term emissions from a source with a deep
layer  of  erodible material,  such  as agricultural soils,  the
resuspension  rate concept  no  longer  applies  and  a  different
formulation is presented.  This latter model is a simplified form
of the Wind Erosion Equation developed by the U.S.  Department of
Agriculture (DOA), and is a forerunner of the "unlimited" erosion
potential model discussed below.

A study by  the Dynamac Corporation  (EPA83) concluded that,  as of
1983, no model had been validated for predicting chronic windblown
particulate emissions.  The report had  the  most optimism about the
DOA  Wind  Erosion Equation,  but  cautioned that  further  work  was
needed to determine the input parameters that would be applicable
to waste sites.
                                15

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3.3.3  DOA Wind Erosion Equation

The  Soil  Conservation Service  (SCS)  of  the DOA has  developed a
procedure for estimating annual soil loss due to wind erosion, the
aforementioned Wind Erosion Equation. This equation expresses the
soil loss as a function of five empirical  factors, each of which is
determined  either  by algebraic relationships  between measurable
parameters or by means of maps, nomograms  or numerical  tables.  The
Wind  Erosion  Equation  combines  soil losses  due  to the  three
processes of saltation, suspension, and creep.

The   National   Agronomy   Manual   (DOA88)   presents   detailed
instructions,  including the necessary charts,  tables  and graphs,
for  determining or estimating each of the  parameters that enter
into the equation.  The form of the functional relationship between
the  soil  loss and  the  five parameters  is not presented  in the
manual - the actual erosion estimates may be obtained from tables
generated  by  the  Agricultural  Research  Service's  (ARS)  WEROS
computer program.   (Given  the  large range  of  values of the input
parameters, several hundred individual tables might be required.)
Alternatively,  soil  losses can be calculated with a slide-rule
calculator called the Wind Erosion Calculator, which was developed
by SCS, ARS  and the  Graphic Calculator Company for this purpose.
A simplified version of the equation is shown as eq. (4-1), below.
                                16

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                            Chapter 4

             EPA-ADOPTED PARTICULATE EMISSION MODELS

During the past decade, Cowherd et al., with the Midwest Research
Institute (MRI) ;  have conducted field investigations of particulate
emissions from various  sources.   These studies,  sponsored by the
EPA, have led to  the  development of emission models for a number of
sources.  An early discussion of these models appears in a report
on the rapid assessment  of exposure to particulates (EPASSa).  Most
recently, the EPA has issued standardized guidance to support the
planning of  remedial action  activities at NPL sites (EPA93a, b).
One  of  the  documents  provides   the  methodology  for  deriving
particulate  emission factors.    Finally,  additional models are
presented in Control of Open  Fugitive Dust Sources (EPA88a).  Many
of the models from the latter report are reproduced in the guidance
document for hazardous waste TSDF  (EPA89a).  A number of the models
have  been  incorporated into  the Compilation  of Air  Pollution
Emission Factors, AP-42  (EPA85b, EPA88b, EPA90, EPA91).   Relevant
excerpts  from the cited documents  are  attached to the  present
report.

4.1  Natural Occurrence:  Wind Erosion

4.1.1  Open Areas

In the course of  their studies of particulate emissions, Cowherd et
al. have developed models for the release of fugitive dust caused
by wind erosion of open areas (EPA85a,  EPA88a,  EPA89a).  Areas are
characterized as having either a "limited" or an "unlimited" wind
erosion  potential.   An example of  an area with an "unlimited"
potential would  be  a   smooth  field,  devoid of  vegetation,  and
covered with a thick layer of loose sandy soil.  In such a field,
relatively low wind  speeds will cause suspension by the action of
saltating particles, as described in para. 3.3.1, above.  Because
of the large reservoir of erodible particles, the erosion rate will
vary as  a function  of  the wind speed,  and  will not appreciably
decrease with time.   An  example of an area with  "limited" potential
would be  an inhomogeneous field  covered with a  high density of
gravel, rocks or clumps of vegetation.   Because they are partially
sheltered  from  the wind and  from  the  cascade  of  saltating
particles, the fine particles interspersed among these non-erodible
elements  require higher wind  speeds for suspension.   Once such
winds occur, the supply of erodible particles is quickly exhausted
and emissions stop until the area is disturbed and a fresh supply
of suspensible particles is brought to the surface.

A detailed  procedure for determining the  erosion potential of a
particular area is presented  in EPA88a,  pp.  6-1 to 6-7.  Note that
in the  next to last paragraph  on p. 6-2,  in  the line  beginning
"catch amounts,  following ...   ",  "Figure 6-1" should be "Figure
6-2".  A more legible version of Fig. 6-1 (p. 6-3) can be found in

                                17

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EPA89a, p. 4-9.  Appendix C.3, EPA88b, presents a silt analysis
procedure that might also be used for the soil analysis discussed
in EPA88a.

The methodology for determining emissions from areas of "limited"
erosion potential is described in EPA88a, para. 6.1.1.  Numerical
values for the erosion potential function described in Eg. 6-3 on
p. 6-11 are tabulated on p.  4-8.  An identical discussion is found
in EPA89a, para. 4.2.1.  This material was also incorporated into
AP-42 (EPA90, para.  11.2.7).  It  is nonetheless necessary to refer
to EPA89a, since the graph (EPA89a, p. 4-9) needed for determining
the threshold friction velocity was omitted from AP-42.

The methodology  for areas of "unlimited" erosion  potential  is a
simplified version  of  the DOA Wind  Erosion  Equation.   A detailed
explanation of the procedure appears in EPA88a, para. 7.1.2, where
the following version of the equation is presented:

     E  = k • a • I • K • C • L' •  V                     (4-1)

     E  = soil particles lost to wind erosion, tons/acre/year.
     k  = particle size factor,  unitless.
     a  = TSP fraction of soil lost to wind erosion, unitless.
     I  = soil erodibility,  tons/acre/year.
     K  = surface roughness factor,  unitless.
     C  = climatic factor, unitless.
     L' = unsheltered field width factor, unitless.
     V' = vegetative cover factor,  unitless.

The specific sections of EPA88a are contained in Attachment 1.

The following modifications to the procedure are recommended.

     Eq.  (4-1)   should  be  modified  by  the  inclusion of  three
     additional  factors;  R,   A, and c.   The  new form  of the
     equation is then:

     E  =k-a-I-K-C-L'-V'-R-A'C        (4-2)

     E = annual emission of total suspended particulates (TSP), kg.
     R = knoll erodibility adjustment factor, unitless.
     A = site area, m2.
     c = conversion factor,  ton/acre to kg/m2 = 0.224.

     Where the other terms are as previously defined.

     Retaining R, the knoll erodibility adjustment factor, in the
     original DOA equation enables a more accurate estimate of TSP
     emissions from short,  windward-facing slopes  which  have an
     increased wind erosion potential. Values for R are listed in
     DOA88, Table 502-1 (p.  502-18) - their use is explained in the
     accompanying text (pp.  502-16/18) (see Att. 4 to the present

                                18

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     report) .   R =  1 if a  knoll erodibility adjustment  is not
     appropriate or if the required data is not available.

     Inserting A, the area of the site, converts the emission rate
     per unit area to total annual emissions.

•    The factor c is a calculated value which converts tons/acre to
     kg/m2 .  The value k = 1 should be used  to calculate the annual
     emission  of TSP. (The  value of k  =  0.5 is  recommended in
     EPA88a to determine the respirable fraction.)

     Fig. 7-4 (EPA88a, p. 7-13), a map for determining the climatic
     factor  (C) ,  should  be replaced with  the updated  -  and much
     more legible - four-color map in DOA88, Exhibit 502.63(a).  To
     calculate  C from  local meteorological  data  using Eq.  7-2
     (EPA88a,   p.   7-10),   the  formula   for   the   factor  PE
     (Thornthwaite's precipitation  -  evaporation  index)  might be
     more easily evaluated  by the  formula  on p.  502-24  (DOA88),
     than by  the one on p. 7-12  (EPA88a)  - both  formulae  should
     yield the same value.

•    The factor V, a function of the amount of vegetative cover,
     may be the  most  difficult  to estimate, especially since the
     amount of cover will usually  vary during the course of a year.
     Assigning this  factor  a value V = 1 (i.e.,  no  cover)  will
     result in a conservative estimate of the emissions.

The  DOA is currently developing a new Wind Erosion  Prediction
System to replace the Wind Erosion Equation. The MRI is currently
updating para. 11.2 of AP-42, which deals with fugitive dust. The
MRI  has advised  the EPA  to wait  for the  DOA to complete the
development of  the new system before  including the soil erosion
model in AP-42  (KIN92).

4.1.2  Open waste and storage piles (except uranium ore and mill
       tailings)

The guidance  for calculating fugitive dust emissions  due to wind
erosion of  open waste piles  (EPA89a)  presents  methods which are
identical to the ones  for open aggregate storage  piles described in
EPA88a and reproduced in EPA90.   These methods include the method
used for  open areas  with  "limited" erosion  potential,  with the
additional consideration of the height and  contour  of the pile, as
well as a separate  method for  continuously active piles.   The
methods are described in detail  in  EPA88a, para.  4.1.2 and para.
4.1.3  as  well  as in  EPA89a, para.  3.2.2  and  para.  3.2.3.  As
mentioned before, these methods also appear in AP-42 (EPA90, para.
11.2.7) but the omission of a needed figure, as well as some errors
in the  formulation of mathematical expressions in the discussion of
waste piles, make this document impractical to use.
                                19

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4.1.3  Uranium ore and mill tailings

NRC  Regulatory  Guide 3.59  (NRC87,  pp. 3.59-11/14)  presents the
methodology  for  estimating fugitive radionuclide  emissions from
uranium  mill tailings  and ore  pads.    This  release model  was
validated by measurements at uranium storage sites and is therefore
preferable to the generic dust release models discussed above.

The principal parent radionuclide (U-238)  in ores is  assumed to be
in  secular  equilibrium  with  its  progenies.    The  following
radionuclides are assumed to be in secular equilibrium with U-238,
they include: Th-234, U-234,  Th-230, Ra-226, Pb-210, Bi-210, Po-
210.  Radioactive daughter products with  half-lives of less than
five minutes as  well as  Pa-234, which has  a  branching  ratio of
0.16%, are excluded  from this  list,  since they are unlikely to pose
significant  health  risks in  comparison  to the  more abundant or
longer lived species.   Radon  (Rn-222), which  is exempt  from the
regulations  of 40 CFR 61, Subpart H,  is  also excluded;  however,
radionuclides resulting from the decay of Rn-222 in  piles which are
subsequently blown offsite are not exempt and are included in the
list.   Not  all  of  the  radionuclides  listed pose  a significant
health risk,  for example, Regulatory Guide 3.59 mentions only U-
234, Th-230, Ra-226, Pb-210,  and Po-210.

4.1.4  EPA Soil Screening Guidance

In support of its activities  on remedial action at NPL sites, the
EPA issued standardized guidance establishing soil screening levels
(SSL) for various exposure pathways and contaminants (EPA93a).  The
primary purpose  of  the  SSL is to accelerate the decision making
process by determine whether  a contaminated site requires further
considerations under CERCLA.   One of the SSL criteria provides the
methodology  for deriving particulate emission factors (PEF).  The
PEF represents an annual  average emission rate for sites of varying
sizes and aspect ratios for rectangular sites.   The  PEF were
derived using normalized (via  regression analysis at  the 95% upper
confidence level) mean concentrations of the contaminants based on
unit  soil  concentration  (mg/kg) .    The  PEF  also   reflect  the
configuration  of   the   site,   size,   receptor   location,   and
representative meteorological data.   The  methodology,   look up
tables,  and factors  for various sites are described in a companion
document  (EPA93b).

The particulate emission factor is derived as follows:

     PEF = (Q/C)  •  3600 -5- [0.036  •  (1-G)  •  (U,/Ut)3  •  F(x) ]   (4-3)

     PEF   = particulate emission factor, m3/kg.
     Q/C   = inverse of  mean concentration at the center of a site,
             g/m2-s  per  kg/ra3.
     G     = fraction of vegetative cover, unitless.
     Um     = mean annual wind speed, m/s.

                               20

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     Ut    = equivalent threshold value of wind speed at 10 m, m/s.
     F(x)  = wind function dependent upon the ratio of uyu^ based
             on Cowherd  (EPA85a).
     3600  = seconds per hour.
     0.036 = assumed respirable  fraction, g/m2-h.

For a 30-acre site, particulate  emission factor is:

          3.85 x 10*8 m3/kg, or equivalent to: 2.6 /*g/m3;

assuming the following arbitrary parameters:

     Q/C   =  40.7 g/m2-s per kg/m3.
     G     =  0.5
     Um    =4.9 m/s
     Ut    =11.3 m/s
     F(x)  =  0.259

It should be noted that this methodology does not provide the means
to directly derive PEFs even if site  contaminant levels are known.
However, the method does  provide  the means to evaluate the relative
impact  of  site  configuration,  size,  and  receptor  location on
particulate  emission  rates.  The evaluations may  be conducted by
using look up tables, equations, and regression curves contained in
the companion document (EPA93b)  to the SSL guidance  fact sheet.

Finally,  the  results  could  be  used   to   approximate airborne
concentrations by multiplying the  particulate emission factor by
the average specific activity of each radionuclide.  For example,
assuming  a  soil 226Ra  specific  activity of  1 pCi/g and  the PEF
derived above,  would yield an average airborne  concentration  of:

     CRa   =2.6 /xg/m3  •   10'6 g//zg •   1 pCi/g

     CRa   = 2.6 x 10'6 pCi/m3

4.2  Soil and Material Handling

The methodology for  estimating fugitive dust emissions from  soil
and material handling  operations is  based on actual measurements
taken while the activity was  in progress.  Many of the studies  were
performed by the MRI,  under contract with  the  EPA.   Most of the
data were taken using the exposure  profiling technique. Multipoint
near-source ambient measurements are  made over 90% of the effective
cross-section of plume at a location typically five meters downwind
of the source.   In the case of a virtual  point source (a stationary
activity  confined  to a  small area), a  two-dimensional array of
samplers was employed, while for a line source (e.g., an unpaved
road with vehicular traffic), a one-dimensional  vertical array was
used.  Simultaneous measurements of  wind velocities were made at
various points to produce  a wind profile,  assuming  a logarithmic
wind  speed  distribution.    After the  data  was  gathered,   each

                                21

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individual concentration  value was combined with  the calculated
wind speed at  the sampler location and converted  to an exposure
value in units of g/m'-s.   The total mass flux from the source was
determined  by  performing  a  numerical  integration,  spatially
integrating the concentration over the effective cross-section of
the plume (KIN92).

The  fugitive  dust  emission  factors  cited  in  the  following
paragraphs,  most  of  which appear in AP-42,  represent the latest
published information  (Note:  The AP-42  report is  scheduled for
revision in late  1994). The MRI is in the process of carrying out
many more tests,  so that  a large increase  in the  data  base is
expected in the next few years.

The AP-42 report also presents information on control methods, see
Section 4.4,  below.

4.2.1  Soil removal and haulage

Cowherd  et  al.  (EPA89a,  p.  3-5) cite  a formula  for estimating
fugitive dust emissions from adding or removing materials from an
open waste pile.   This is the same formula  that  is presented in
AP-42 for aggregate  handling  and for  continuously active storage
piles (EPA88b, para.  11.2.3.3).  This general procedure should be
applied  to  estimating  fugitive  emissions  from the  operation of
removing soil from storage piles.  The movement of trucks on site
should be modeled by the  emission  factors for unpaved  roads,  a
discussed in para. 4.3.1,  below.

4.2.2  Grading and shaping of soil

Cowherd et al. (EPA89a, para.  5.2.1)  recommend an emission factor
for lift construction at hazardous waste landfills which was based
on field measurements of emissions from bulldozing the overburden
at Western coal  mines.   The  emission factors  for different size
particles are  found  in EPA91,  p.  8.24-4.   These emission factors
should be applied to the grading and shaping of soil on site.

4.2.3  Agricultural tillage and seeding

AP-42  (EPA85b,  para.   11.2.2)  describes  the  methodology  for
estimating fugitive dust emissions from agricultural tilling.  This
method should be used to estimate the emissions  during the phase of
site reclamation when soil is  being prepared  for seeding.  Grading
operations are discussed in the preceding section.

4.2.4  Building demolition and material disposal

In the absence of specific data  for  dismemberment of buildings,
Cowherd et al.  (EPA88a, p. 5-3), recommend the use of the materials
handling equations cited in para. 4.2.1, above.   The loading of the
debris following demolition is modeled in EPA88a, para. 5.1.2.3 by

                                22

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the following equation:

     Ed = 0.029  •  L                                       (4-4)

     E  = TSP emission, kg/m2.
     L  = waste material load per floor space unit area, Mg/m2.
        = 0.45  (default value in absence of site-specific data)
  0.029 = default average emission factor, kg/Mg.

Any pushing operations  (e.g., use  of a bulldozer)  related to the
demolition  should be modeled  by the  method described  in para.
4.2.2,  above.    Default values  are presented  in  EPA88a,  para.
5.1.2.5.   The emissions resulting  from the on-site  movement  of
trucks  should be  estimated according to  the methods  for unpaved
roads,  described  in para.  4.3.1,  below.   EPA88a,  para.  5.1.2.4
lists  default  values  to  be   used if   site-specific  data  are
unavailable.

In practice,  however,  emission rates may be mitigated  to reduce
fugitive  releases   to   limit   exposures  to   workers   or  meet
environmental   protection   standards.   The   facility    may   be
decontaminated before the onset of the demolition work. A temporary
containment may be erected over the  facility being demolished,  or
water may  be used  as  a wetting  agent to reduce  dust  loadings.
Accordingly, these measures may result in lower emission rates.
The emission  rate can also be modified to account for  the total
area  of the  facility  being demolished.  Equation  (4-4)  is then
modified as follows:

     Edm = °*029 ' L  • M  • A                              (4-5)

     Edm = TSP emission,  kg/event.
       M = Mitigation factor, unitless.
       A = building or total floor space area,  m2 .

      Where the other terms are as previously defined.

4.3  Non-intrusive Action

4.3.1  Vehicular traffic on unpaved  roads

The  methodology  for calculating  fugitive  dust  emissions from
vehicular traffic over unpaved roads  is presented in AP-42  (EPA88b,
para. 11.2.1.2).  Cowherd et al. (EPA88a, p.  3-4), while agreeing
that  the AP-42  method  is  acceptable  for  continuous  traffic,
recommend using  a  value of  zero  for the  number of  days with
measurable precipitation to  arrive  at  a conservative estimate of
annual  emissions  due to intermittent traffic.   A  good general
discussion of this  topic is presented in EPA88a,  Ch.  3,  while a
similar discussion, focused on hazardous waste TSDFs, is found in
EPA89a, para. 2.2.
                                23

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4.4  Control Methods

The AP-42 (Sect. 11.2)  report also presents  information on the use
of control  methods to reduce emissions rates  (EPA85b).   Typical
control  methods  include the  use  of water,  chemical  binders,
vegetation covers, windbreaks, and enclosures.  Water,  as a wetting
agent, is most commonly used, but the reduction is short-lived.
Water acts as dust suppressant by  forming cohesive moisture films
among grains  of soil.  Chemical binders,  however,  provide longer
lasting  reductions.   Between applications,  the  effectiveness of
such dust suppressants decreases  with increasing  traffic.  Other
competing forces include evaporation and drainage or migration to
deeper soil layers.  The use of  binders may be problem as it may
have  adverse   effects   on   soils,  plants   and  result  in  the
introduction  of other contaminants.   The use of  windbreaks and
enclosures are  relatively more expensive  and their effectiveness
must be evaluated for each application.  Table  4-1 summarizes some
of the information presented in the AP-42 report.


Table 4-1  Summary of AP-42 Emissions Control Measures'8'
Conditions
 Methods
 Effectiveness
  Reduction
Unpaved roads
Agricultural
 soil

Storage piles
Heavy construc-
 tion

Paved roads
water
 chemicals

vegetation,
 windbreaks

 watering &
 chemicals

 twice daily
 watering

 watering
 twice/wk
short-lived
 longer-lived

varying
 good
 fair
 fair
not significant
  some benefit

not significant
  up to 90%


  up to 50%


  up to 50%
(a) Extracted from Section 11.2 of AP-42 report  (EPA85b).
                                24

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                            Chapter 5

                MECHANISMS  OTHER THAN RESUSPENSION

5.1  Evaporation From Ponds and Lagoons

The evaporation of water from ponds and lagoons is governed by the
air  temperature,   vapor pressure,  dew  point,  wind  speed,  and
insolation.  Complex relationships have been developed to estimate
the evaporation rates for lakes and the so-called "pan evaporation
rates."  Tables have been developed to provide the information by
state or climatic  regions  of  the U.S.  Among other sources, this
information is available in the Water Encyclopedia  (Table 2-48 and
Fig. 2-11,  LEE90)  and in an EPA  report  (Fig. 5-1,  EPA88a) .  The
Water Encyclopedia also provides the methodology to calculate lake
and pan  evaporation rates when  site specific data are available
(Table 2-49, LEE90).

AP-42 and other EPA documents provide guidance for estimating the
emissions of volatile organic compounds from waste-water treatment
facilities and other sources.  These models are not applicable to
the emission  of some  nuclides, .e.g.,  tritium,  which is  not an
organic compound.

5.1.1  Evaporation models

Tritium, in the form of tritiated water  (HTO),  is the principal
radionuclide which can be released by evaporation or volatilization
from open  bodies  of  water such as ponds  and lagoons.   (HTO is
simply H20  with one of the hydrogen atoms,  1H replaced by tritium,
3H).   Since HTO is chemically almost indistinguishable from water
(there are some very slight differences in  the chemical properties
of  different  isotopes), the  most appropriate way to model its
release is to assume that the water vapor emitted from the surface
of a pond has the same specific activity of tritium as the water in
the pond itself.

Wing (NRC79) surveyed several evaporation models and compared the
published  experimental  observations  on the  evaporation  of water
from drying trays with  the model predictions (see Attachment 5 in
this report.)   Only the equation from  a  work by  Eckert and Drake
yielded a  rate that was within  10% of the experimental  results.
Wing then used this equation to calculate annual evaporation rates
at ten different locations  in the U.S.,  using annual average values
of wind speed,  temperature and relative humidity, and compared the
results  with   measured  evaporation  rates.   Although the  model
calculations were  lower than the published data in nine  of the
cases, the worst prediction was only 47% below  the actual value.
Using annual average meteorological conditions rather than using
hourly data and integrating the evaporation rate over the  entire
year may have contributed to the discrepancy.
                                25

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Several factors which  appear  in  the published equation have been
combined, while other factors,  representing physical properties of
air and water,  have been replaced with accepted  values of these
properties.    The  result  is  the  following  formula  for  the
evaporation rate from a circular pool:
     E = 20.73 •  Ps •  A0'9 •  U°'8 4- T1'47                    (5-1)

     E  = evaporation rate of water, g/s.
     A  = surface area of pool, m2 .
     PS = equilibrium vapor pressure of water at ambient
          temperature, mm Hg.
     U  = wind speed, m/s.
     T  = absolute temperature, in  *K.
        = ambient temperature, in *C + 273.2.

This  model  assumes  that  the  water  and  air  are  at the  same
temperature, ignoring that evaporative cooling would tend to reduce
the  vapor pressure  and  hence  the  evaporation rate.   The  net
evaporation rate is a balance of evaporation from the surface and
condensation onto the surface from the ambient water vapor in the
atmosphere. However,  only the one-way process, which will be called
the surface volatilization rate,  is the pathway  for  the  release of
tritium, as ambient water vapors are assumed to be free of tritium.
This rate corresponds to evaporation under zero ambient humidity
and is conservative,  since in reality some of the tritiated vapor
will recondense,  reducing the net flux.

To calculate  the  emission rate of  tritium,  the evaporation rate
multiplied by the specific activity of tritium in the water.

     R = E •  a                                           (5-2)

     R = emission rate of tritium,  pCi/s.
     E = evaporation rate of water, g/s.
     a = specific activity of tritium in water,  pCi/g.

Ideally, the annual emissions should be calculated by integrating
the  emission  rate,   using  hourly   average   wind  speeds  and
temperatures  and  specific  activities  measured  at  various  times
during the year.

The concentration of tritium in the atmosphere is governed by the
presence  of  airborne  water  vapors.   There is  no  significant
fractionation when mixing natural  and tritiated water.  However,
some fractionation may occur when tritiated and  natural  water pass
across a liquid-gas interface. Because of the difference in mass,
the vapor pressure of tritiated water is about 90% that of normal
water at environmental conditions.  The concentration of  tritium in
the  atmosphere  (pCi/m3)  is dependent on  the   concentration of
tritium in atmospheric  water  (pCi/L)  and absolute humidity. This
relationship is expressed as:

                                26

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     Cfl = Cw  • Hfl •  10'3                                 (5-3)

     Ca = tritium concentration in the  atmosphere,  pCi/m3.
     Cu = tritium concentration in atmospheric water vapor, pCi/L.
     H  = absolute  humidity,  g/m3.
   10"? =  conversion factor,  L/g for water.

The concentration of tritium in atmospheric water may be obtained
by sampling and analysis (NRC83) or estimated to reflect specific
processes  or release mechanisms.   Absolute humidity  values are
known to vary significantly depending upon geographical locations
and seasons, ranging from 3.0 to 16.5 g/m3 in the continental U.S.
(NRC83, Fig. 2.15).  The NRC  uses a default value of 8.0 g/m3, when
site specific data are not  available  (NRC79).  More information on
the behavior of tritium is  provided in  NCRP Report No. 62, Tritium
in the Environment (NCRP79).

Some  DOE  facilities,  notably  the Nevada  Test Site,  calculate
tritium emissions by assuming that the entire tritium activity that
is discharged into the pool during the year evaporates during the
same year  (DOE92) .   This method is said to be conservative in that
loss of tritium through ground seepage  is neglected. This would be
a valid method if neither the volumes nor the specific activities
of the liquid effluents varied  from year to year,  and  if the volume
of the pool and specific activity of the water in  the pool remained
constant.  Both methods may be used and the results that yield the
more conservative estimate  should be reported as the emission rate.

Another method would be to estimate the evaporation rate by using
evaporation  rates  from the Climatic Atlas of  the  United States,
published by the U.S. Department of Commerce.  These data may not
be current, however,  nor sufficiently site-specific.  Furthermore,
they  represent  only  the net  evaporation  rate  -  their  use may
therefore produce an underestimate of the tritium release rate, as
discussed above.

5.1.2  Wet-Cooling Towers

Wet-cooling towers are heat-exchangers used to dissipate large heat
loads from industrial  processes.   Water  is used as the medium to
transfer heat away from coils,  in which process fluids flow.  Under
normal conditions, the two fluids never mixed.   In the event of a
leak, the cooling fluid may become  contaminated  by  the process
fluid.  Within the  tower, some  of the cooling fluid  are drawn up as
droplets  by  convection currents  and  are  released  as  "drift"
droplets.  The droplets are  then  carried  downwind.  On the other
hand, the  larger droplets  settle  out of  the air and deposit near
the tower.  Some  towers are equipped with drift or mist eliminators
to minimize such emissions.
                                27

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As the water evaporates, the droplets leave behind fine particulate
matter formed by the crystallization and agglomeration of dissolved
solids.   Dissolved solids  may include minerals,  chemicals  from
corrosion  and  algae  inhibitors,   etc.    Emissions from  cooling
towers, therefore, might be  modeled  as  PM.0 particulates (EPA91).
Given that the size of the  droplets vary,  it also follows that the
fine particulate matter formed by dissolved solids would have its
own particle size distribution.

In Supplement D to AP-42,  the  EPA has estimated that the overall
emission rate to be about  2.3  x 10"3  g per L of circulating water
flow, based on limited data for induced draft cooling towers (Sect.
11.4, EPA91).   However,  no data were provided  for natural draft
cooling towers.   The  rate given by the EPA is also believed to be
typical of older towers with less efficient mist eliminators.

The emission  of radioactivity  from wet-cooling towers is further
complicated  by  the possible speciation of radioactivity  in the
circulating  water.    For  example,  some  radionuclides,  such  as
uranium, cesium, iodines, etc., may chemically bind with minerals
or chemical  inhibitors.  Furthermore,  it  is  not clear if further
nuclide speciation takes place  once the  fine particulate matter is
formed by the dissolved solids  left by the droplets.  On the other
hand, tritium and noble  gases  (e.g.,  xenon,  argon, radon,  etc.),
may be most efficiently dispersed,  since by design, cooling towers
work as very effective aerators.

Given these various considerations, estimating release rates from
wet-cooling  towers  (either  mechanically  induced  or  by  natural
draft) may have to addressed on a case-by-case basis.

5.2  Evaporation from contaminated soil

Evaporation  or  volatilization could  be  a  significant  release
mechanism  of radioactivity  from  contaminated soils  where water
contaminated by  tritium or  carbon-14  has been spilled or otherwise
released.

5.2.1  Saturated soil

The Superfund Exposure Assessment Manual  (EPA88c) recommends that
spills of liquid contaminants where liquid pools are visible on the
soil surface or where the  soil is saturated from the surface on-
down be modeled in the  same manner as open liquid storage pools.
This is also the most conservative model - models for the release
of contaminants from  the pore spaces in the  soil predict lower
release rates.  Furthermore, the soil release models require data
or   assumptions   regarding   the   time-dependent   contaminant
concentrations  and depth profiles.
                                28

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It is therefore  recommended that atmospheric releases of tritium
from soils contaminated with tritiated water be modeled in the same
way as pools containing tritiated water  (see para.  5.1.1).

Another model used to assess the amounts  of radioactivity released
from contaminated soils relies  on the evapo-transpiration rate of
water.  This model,  developed by DOE,  is  used for both tritium and
carbon-14.   The  model is documented in  the  RESRAD computer code
(DOE93, App. E and L).  The  model assumes  that tritium exhaled by
plants is negligible.  However,  for carbon-14,  plants are the sink
since atmospheric UCO2 is incorporated during photosynthesis.

The model for tritium and carbon are similar, the only difference
being on how the tritium  and carbon flux rates are derived.  The
following equation applies to both, tritium  and  carbon-14.

     Ci   = Wfd •  FJ • /A • 3.17 X 10'8 +  Hmjx  • Uw         (5-4)

     Ci   = Average airborne concentration over  area, pCi/m3.
     Wfd   = Wind  frequency  for  receptor  location, unitless.
     Fj    = Contaminant flux rate from soil, pCi/m2-y.
     A    = Size  of contaminated area, m2.
     Hmjx = Mixing height within which contaminant is  uniformly
            distributed, 2 m for human inhalation.
     Ug    = Annual average wind speed, m/s.
     3.17 x 10"8  = conversion factor, y/s.

For tritium, the  flux rate,  F,,  is derived as follows:

     Fj    = WT  •  Et  •  106                                    (5-5)

     Fj    = Contaminant flux rate from soil, pCi/m2-y.
     WT    = Tritium concentration in soil  water,  pCi/m3.
     106  = Conversion factor,  cm3/ro3.

     Et    = Ce  •  [(l-Cr) • Pp +  Ir]                          (5-6)

     Et    = Evapo-transpiration rate, m/y.
     Ce    = Evaporation coefficient, unitless.
     Cr    = Runoff coefficient, unitless.
     Pp    = Annual rainfall  rate, m/y.
     Ir    = Irrigation rate, m/y.

DOE assumes  a  default  evaporation  coefficient  of  0.5.   For the
runoff coefficient, values range from 0.1  to 0.4 for agricultural
soils and woodlands and 0.4  to  0.65 for  urban environments.
                                29

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For carbon-14, the  flux rate,  F., is derived as follows:

     F,   = Sc •  Ec  •   Pb •  ds • 106                        (5-7)

     F;   = Contaminant flux rate from  soil, pCi/m2-y.
     Sc   = Carbon-14  concentration  in  waste,  pCi/g.
     pb   = Soil bulk  density,  g/cm3.
     ds   = Soil depth, m.
     106  = Conversion factor,  cm3/m3.

Additional information of the behavior of tritium and carbon-14 may
be obtained from NCRP  Reports  No. 62  (Tritium  in  the  Environment)
and No. 81 (Carbon-14  in the Environment)  (NCRP85,  79).

5.2.2  Subsurface contamination

In cases where the  surface layer of  the soil is dry and devoid of
tritium, but tritiated water remains below the surface, Eq. 2-3 in
EPA88c  (p. 16) can  be used to calculate a more realistic release
rate than  that produced by  the surface  evaporation  model.   The
value of the diffusion coefficient of water vapor in air, required
in Eq. 2-3, is 0.2  cm2/sec.  The.soil porosity and  the saturation
vapor concentration must also be determined.  The expression is as
follows:

     E,   = D, •  Csj •  A •   (Pt)4/3 •  [M, + dsc]               (5-8)

     EJ   = Emission rate, g/s.
     Dj   = Diffusion  coefficient, 0.2  cm2/s.
     A    = Contamination  area,  exposed,  cm2.
     Mj   = mole fraction  of contamination  in  soil, unitless.
     dsc   = Effective  depth of soil  cover,  cm.

     Pt   = Total soil porosity, unitless.

               = 1  - ft -5- p                                   (5-9)

          /?    = Soil  bulk density,  g/cm3.
          p    = Particle  density, g/cm3.

     C .   = Saturation vapor concentration,  g/cm3.
      SI
               = P  • MW. -5- R •  T                            (5-10)
          P    = Vapor pressure  of contaminant,  mm Hg.
          MWj  = Molecular weight  of contaminant,  g/mole.
          R    = Molar gas constant,  62,361 mm Hg-cm3/mole-°K.
          T    = Absolute temperature,  °K.
                                30

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5.3  Gaseous and Other Types of Emissions

Radionuclides are  released  at the Nevada Test  Site  (NTS)  during
re-entry drilling  and by  ground  seepage  of  noble gases following
underground  nuclear  detonations.     (Some  of   the  following
information  is  based  on informal telephone conversations  with a
number of EPA staff and DOE contractor personnel at NTS.)

5.3.1  Re-entry drilling

Within one to two  days  of an  underground nuclear test, a  hole is
drilled into the hollow  chamber created by the explosion to sample
the non-fissioned material and determine the fission yield.  During
this process, called "drillback", radioactive halogens in gaseous
form  (principally  1-131)  and  noble gases (Xe-133  and Kr-85)  are
sometimes  released.   Although  emanating  from a  small area (a
virtual point  source),  these  releases  are uncontrolled and  not
directly monitored.  They may therefore be classified as fugitive
(though not necessarily diffuse)  emissions.

Apps. 1 and 2,  DOE92,  describe the drillback operations conducted
by  the  Lawrence  Livermore   (LLNL)  and  Los  Alamos  National
Laboratories (LANL).  LLNL uses measurements of the  radiation field
in  the  vicinity  of  the  drill pipe and  ambient air  samples to
estimate the effluent activity.  This estimate is then verified by
the alternative method of  measuring  radionuclide concentrations in
downwind air samples  and  using local wind  data to calculate  the
release rate.

LANL, which uses a different drillback system, samples the ambient
air in the  work  area on top of the drillback  platform  (LANL92) .  If
leakage of radioactive gases is suspected, samples are also taken
from  the   "cellar",   the  subsurface   excavation  housing  the
containment  equipment.      Data   collected   during  the  LOCKNEY
drillback,  at which time a large amount of activity was released,
were used to derive a procedure for inferring effluent activities
from air sampling measurements.  LANL estimates that the releases
calculated by this procedure  are within  a factor of  three of the
actual  amounts  for  modest  releases,  and  within  an order of
magnitude for small ones.

5.3.2  Ground seepage of noble gases

Seepage of  radioactive  noble  gases is sometimes  observed  in  the
Pahute  Mesa  test  area,  beginning a   week  or   more  after an
underground nuclear explosion. An analytical model to explain and
quantify this seepage is being developed  (NIL91, NIL	, BUR89).

According to the current understanding of the release mechanisms,
the collapse of the cavity created by a nuclear  detonation creates
a rubblized zone,  called the chimney, immediately above the cavity.
If  the  volcanic  rock  above the  chimney  contains  fractures,

                               31

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radioactive  noble  gases  can  leak  to  the  surface.  The  normal
cyclical changes in barometric pressure cause the atmosphere to act
as  a piston,  driving air  into the  fractures  or  drawing  gases
contained in these fissures. The rock thus breathes, inhaling air
and exhaling gaseous radionuclides.  However, the observed seepage
is  inconsistent  and the phenomenon  is not yet  fully understood.
The purpose of the model  is to  quantify  the  releases due to this
natural  mechanism  and  thus  ascertain  the  integrity  of  the
containment,   in   compliance   with  regulatory   standards   and
international treaties.

It  should  be  noted that  the seepage of  noble gases may best be
characterized by sampling, followed by analysis.  Some of the major
limitations in conducting this  type of sampling include the proper
selection  of  sampling locations,  orientation of  the  samplers to
reflect  local  atmospheric  dispersion,   effect  of  terrain  on
dispersion, distances  from  seepage points to sampling locations,
and integration of  the results over the area being evaluated.

5.3.3  Emissions from buildings

Emissions from buildings may occur through vents,  stacks or through
natural ventilation. The mechanisms leading to such releases may be
induced mechanically  (e.g., exhaust  fans)  or via  natural  means
(e.g., convection and stack  effect). In simple terms, emissions can
be  estimated  by  determining the  volume  of  material  (air,  gas,
vapor,  etc.)  released, its  concentration,  and  application  of a
mitigation factor,  if warranted. The expression is:
           n
             R,  • T, •  C,  •  M,                              (5-11)


     Eb  = Sum of all  releases over all events i,  Ci.
     R.   = Release rate for event i,  nr/sec.
         = Duration of release i,  sec./event.
     0,.   = Concentration of contaminants for event i,  Ci/m3.
     MJ   = Mitigation factor,  unitless.

For puff releases, the above expression is reduced to:


     E   = 2 V,  •  C. •  M,                                   (5-12)
     Vi   = Volume released in each event i,  m3.

     The other terms are as defined previously.
                                32

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The mitigation factor may be used to account for the use of devices
or process  which reduce the  amount of materials  released.  Such
devices may  include  HEPA filters,  baghouses,  scrubbers,  adsorber
beds, etc.

If the release is monitored downstream of such devices to determine
actual concentrations, the mitigation factor is set to equal one.

5.3.4  Emissions from tank venting

The emission of materials released during  the venting of tanks may
be estimated  by  determining the displaced volume of the overhead
space above  a liquid. As before,  the emission takes into account
the concentration of  the contaminants, partition factor between the
liquid and gaseous phases,  and application of a mitigation factor,
if warranted. The expression is:


     Et  = £ V, • C. • P,  •  M,                             (5-13)
     Et  = Sum of all releases over all venting events i,  Ci.
     Vj  = Volume released for each venting i,  as displaced by
           the amount of liquid added to the tank, m3, and where
           Vj cannot exceed the tank's rated capacity.
     Cj  = Concentration of contaminants for event i,  Ci/m3.
     Pj  = Partition factor for each contaminant, unitless.
     MJ  = Mitigation factor,  unitless.

The partition factor may  vary depending  upon the contaminants,
being  typically  one  for  noble  gases  and  less  than  one  for
contaminants  that are miscible or soluble  in the liquid phase.

The mitigation factor may be used to account for the use of devices
or process  which reduce  the  amount of  materials  released. Such
devices may  include  filters, adsorber beds, traps, etc.

If the release is monitored downstream of such devices  to determine
actual concentrations,  the mitigation  and partition  factors are
each set to  equal one.

For tanks  holding  gaseous  contaminants, the  above expression  is
redefined in  terms of the  gas volume released:


     Eg  = 2 V.  • C,  • P. •  M,                              (5-14)


     Vj  = Gas volume released in each event i, m3,  adjusted to
           normal temperature and pressure or  as measured during
           each  release.

                                33

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     The other terms are as defined previously.

The partition factor is set to equal one for noble gases and less
than one for vapors or reactive gases which may plate-out in tanks.

The mitigation factor may be used to account for the use of devices
or process  which reduce the amounts of  materials released. Such
devices may  include filters, adsorber beds, traps, etc.

If the release is monitored downstream of such devices to determine
actual concentrations,  the mitigation and  partition  factors are
each set to  equal one.

5.3.4T1 Emissions from equipment

Emissions can  also be associated with equipment  used  to process
radioactive materials.   The emissions may be associated with built-
in system features  (e.g.,  filtration systems)  or inherent in the
process  (e.g.,  air  displaced  by  a waste  compactor  ram).   The
mechanisms leading to such releases are similar to that modelled in
para. 5.3.3.  As before, the expression is:


     E   = Z Rj • T. •  C,. •  MJ                             (5-15)
           i
     Ep  = Sum of all releases over all processes i,  Ci.
     Rj  = Release rate for process i,  vr/sec.
     Tj  = Duration of release i,  sec./process.
     Cj  = Concentration of contaminants for process i,  Ci/m3.
     MJ  = Mitigation factor,  unitless.

The mitigation factor may be used to account for the use of devices
or process  which reduce  the  amount of  materials  released. Such
devices may  include  HEPA filters,  baghouses, scrubbers, adsorber
beds, etc.

If the release is monitored  downstream of such devices to determine
actual concentrations, the  mitigation  factor  is set  to equal one.
                                34

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                            Chapter 6

          GUIDANCE ON ENVIRONMENTAL MONITORING PROGRAMS
          TO DEMONSTRATE COMPLIANCE  WITH  THE  DOE NESHAPS

6.1  Summary of NESHAPS Requirements

Paragraph   (b)(5)  of  40  CFR  61.93  states  that  the  use  of
environmental  measurements  at  critical receptor  locations  to
demonstrate  compliance with  the standard   is  subject to  prior
approval of the EPA  (EPA89a).  Applications  for approval must:

     1)   include  a  detailed  description  of the  sampling  and
          analytical methodology, and

     2)   show how the following criteria will be met:

          i)   Measurements  shall  be  made  at  locations of  the
               critical receptor.

          ii)  The  air  at the  point  of measurement shall  be
               continuously   sampled  for   the  collection   of
               radionuclides.

          iii) The  radionucl ides  released  that  are  the  major
               contributors to the effective dose equivalent must
               be collected and measured.

          iv)  Radionuclide  concentrations  that  would cause an
               effective dose equivalent greater than or equal to
               10  percent  of  the  standard  shall  be  readily
               detectable and distinguishable from background.

          v)   A quality assurance program shall be conducted that
               meets  the requirements described  in  Appendix B,
               Method 114, 40 CFR 61.

6.2  Sampling and Analytical Methodology

The stack monitoring and sample collection  methods  described in
Method  114,  Section 2,  and the radionuclide  analytical  methods
listed  in Method  114,  Section 3, can, in  general,  be applied to
environmental measurement of airborne radionuclides.  If the method
provided in  the  application does not conform to  Method 114,  the
procedure for the alternate method must be submitted to the EPA for
further review and decision on its applicability.

Table 6-1 lists the half-lives and modes  of decay of the principal
radionuclides  released  at  DOE facilities  and  identifies  the
physical state of each.  Consideration of  these physical parameters
is necessary to  establish  whether  environmental  monitoring  for
determining compliance will be feasible.

                                35

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Table 6-1  Physical Parameters of Selected Primary Radionuclides
  Decay Mode
                           Particulates
          U-234
          U-235
          U-238
          Pu-238
          Pu-239
          Am-241
          K-40
          Co-60
          Sr-90
          Sb-125
          Pb-212
          H-3  (H2)
          C-ll
          N-13
          C-14  (C02)
          0-15
          Ar-41
          Kr-88
          Xe-133
          H-3  (H20)
     2.4 E+5 yr
     7.1 E+8 yr
     4.5 E+9 yr
     8.8 E+l yr
     2.4 E+4 yr
     4.3 E+2 yr
     1.3 E+9 yr
     5.3 E+0 yr
     2.9 E+l yr
     2.7 E+0 yr
     1.1 E+l hr
                               Gases
     1.2 E+l yr
     2.0 E+l min
     1.0 E+l min
     5.7 E+3 yr
     1.2 E+2 sec
     1.8 E+0 hr
     2.8 E+0 hr
     5.3 E+0 day
                            Liquids/Vapors
1.2 E+l yr
     Alpha
     Alpha
     Alpha
     Alpha
     Alpha
     Alpha
     Beta, Gamma
     Beta, Gamma
     Beta
     Beta, Gamma
     Beta, Gamma
     Beta
     Positron
     Positron
     Beta
     Positron
     Beta, Gamma
     Beta, Gamma
     Beta, Gamma
Beta
(a)  See text for details.
(b)  Exponential notation,  2.4  E+5  means 2.4 x 10"
                                36

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6.2.1  Radionuclides as particulates

The radionuclides of greatest concern at many DOE facilities, often
uranium-234  and/or uranium  238,   are  particulates.   To  sample
particulates, air is pulled through a high-efficiency particulate
filter using a calibrated  high-volume  air  sampler.   The sampling
rates  (volume of  air  per  unit  of  time)  should  be  recorded
periodically, and the total volume of air sampled is based on the
average of the recorded flow rates.

For radionuclide  analysis,  the air filter may be equally split into
at  least  two  halves,  and each  analyzed  separately:   1)  as  a
duplicate  analysis;  2)  as a  cross-check  analysis  for the  QA
program; or 3) to be retained for re-analysis or conducting other
types of analyses.  The  volume of air sampled may be assumed to be
proportional to  the mass  of the  filter fraction of  each filter
section, unless data and filter conditions show otherwise.  Also,
composite  filter samples  can  be  used for measuring long-lived
radionuclides.

6.2.2  Radionuclides as gases

Tritium, as water vapor, can be collected by the methods described
in Section 2.2.1  of Method 114.  To measure total tritium in air
sample  (tritiated water vapor  plus elemental tritium,  2H),  the
sampling system requires an oxidizing bed to convert any elemental
tritium  into  water followed by  a  zeolite  bed,  for  example,  to
absorb the tritiated  water that was initially  present in the air
and that formed  from  the oxidation of 2H  in the  sampling system.
Because elemental tritium may  remain as 2H for extended periods of
time, the method should:

     1)   measure   both  chemical   forms   of   tritium   in  the
          environment; or

     2)   increase the measured environmental tritiated water vapor
          concentration  by the  activity ratio  (total tritium vs
          tritiated water vapor), measured at the  point of release;
          or

     3)   show  that  concentrations  of  elemental  tritium  are
          insignificant  at the  environmental  sampling  location
          relative to the tritium present as water vapor.

Carbon-14 in environmental  airborne  samples can be considered to be
in the form of carbon dioxide  (C02)  and sampled as carbon dioxide,
see Method 114, Section 2.2.4.
                                37

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Applying cryogenic techniques to sample radioactive noble gases are
usually impractical at most locations in the environment and away
from the plant.   Therefore, a  sampler that collects a controlled
volume of  air at  specific  time  intervals may be acceptable and
considered  a  continuous  sample  for  this purpose.    Cryogenic
techniques, along with liquid scintillation counting, may be used
to separate  and  measure  noble gases, as  see  Method 114,  Section
2.2.3.

Again, it  may not be practical,  nor  possible,  to  collect and
measure short-lived gaseous radionuclides in environmental samples.
These  radionuclides  are  primarily  oxygen-15,   carbon-11,  and
nitrogen-13  (see Table 6-1).  Although the half-lives of argon-41
and krypton-88 are much longer (2-3  hours),  their measurement in
the environment on a continuous basis is also  impractical.  As the
sample collects,  the radioactivity rapidly decays, and in a short
time an equilibrium is established when  the collection is equal to
the  decay  rate.   Thus,  there  is  a  limit  to  the  quantity  of
radioactivity that can be collected,  as well  as  that which occur
during dispersion from the source to sampler.   For these reasons,
demonstrating  compliance  by measuring  the  following short-lived
radionuclides in situ is usually not a practical option:

               Radionuclide        Half-life

               oxygen-15           120 seconds
               nitrogen-13         10 minutes
               carbon-11           20 minutes
               argon-41            1.8 hours
               krypton-88          2.8 hours

Except for possibly  a  few DOE  facilities, radiation exposures to
the maximum  exposed  individuals  due  to these short-lived gaseous
radionuclides are not significant when compared to the 10 mrem/yr
limit.

6.3  Criteria for Environmental Monitoring Programs

6.3.1  Measurements made at critical receptor locations:
       How should locations be selected?

For facilities with continuous emissions,  the  critical receptor
locations may be either:

     (a)   the location of the highest X/Q on the facility perimeter
          fence line; or

     (b)   the  location  of  the   highest   off-site   X/Q  where  a
          residence, business, or school exists.
                                38

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In case b) ,  the sampling location may be placed at any site between
the highest  off-site  X/Q  and the fence line,  if this  would make
sampling easier, more convenient, and cost-effective.

Acceptable dispersion models  (e.g.,  AIRDOS-PC,  CAP88-PC,  COMPLY)
may be  used to  determine the highest  X/Q location(s) .    If the
highest X/Q location is represented by several sites with similar
values, measurements should be required at all such sites until the
location with  maximum X/Q can be definitely identified (one year
minimum sampling).  Sampling is then required at only the maximum
X/Q site, unless conditions change.  The same procedure should be
followed when fence-line measurements are used (case  (a) above) and
the highest concentrations are computed to be similar within two or
more of the 16 sectors.

For  facilities  with  intermittent  or  variable emissions,  many
locations around the facility (at least one within each of the 16
sectors) should be monitored.

6.3.2  Continuous sampling at the point of measurements:
       What represents continuous sampling?

There may be valid and acceptable reasons  for the sampling systems
at a  facility to be  off  line for  short periods of time (e.g.,
filter or sample changes,  maintenance, calibration,  etc.).  Under
many circumstances,  the requirement for continuous sampling can be
satisfied when the 95 percent data completeness requirement is met.
This means that the  time the sampling system is not in satisfactory
operations should not exceed 5 percent of the sampling period.

The 95 percent figure is intended to provide uniformity in dealing
with various  co-located  facilities  or multiple release  points.
More  restrictive conditions  may be  required  if  a facility is
approaching  the  dose  limit or  when  in non-compliance.    If
necessary, a backup sampler may  be placed in operation to insure
that sampling is accomplished during the balance of the time (i.e.,
5 percent).

6.3.3  Sampling and measurements of major radionuclide contributor:
       What radionuclides does this include?

The radionuclides that contribute significantly to  the effective
dose  equivalent  typically  include   particulate   and   gaseous
radionuclides  and  tritium  (see  Table 6-1).   All   of  the listed
particulate radionuclides and tritium can be readily collected and
measured by routine sampling methods.   For all other gases listed,
only xenon-133 has a half-life sufficiently long to permit  it to be
collected in the environment and analyzed in a laboratory.
                                39

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6.3.4  Radionuclide concentrations causing an effective dose
       equivalent of 1 mrem/yr must be readily detectable and
       distinguishable from background: How should this be
       determined?

Environmental monitoring programs are typically judged to meet this
criterion if the "lower limit of detection" (LLD) of the sampling
and analysis methods  is 10 percent or  less  of the Concentration
Levels for Environmental Compliance listed in Table 2, Appendix E
of  the  40  CFR part  61.    The  LLD  is  defined  that  nuclide
concentration that is discernable from background at a confidence
level of 95 percent (i.e., the net activity value is greater than
a specified value above  the  random fluctuation of the background
count-rate).  The LLD is calculated as follows:

                    4.66 • Sb
     LLD =                                               (6-1)
            2.2 x 1012 • E  • V • Y  • em

     LLD = lower limit of detection, Ci/m3.
     Sb  = standard  deviation of the background or blank  count
           rate, cpm.
     E   = counting efficiency, cpm/dpm.
     V   = sample volume, m3.
     Y   = radiochemical yield, if applicable, unitless.
     A,   = radioactive decay constant, time '}.
     At  = time elapsed between midpoint of sample collection and
           time of counting,  time.
     2.2 x 1012  = conversion factor, dpm/curie.

The value  of Sb should be based  on the standard  deviation of a
series  of  blank measurements  using  the  same  type of  sample
collection media (e.g.,  an air-particulate filter) carried through
the complete analytical procedure.

If the  application  for  approval  does  not list  an  LLD  for the
sampling  and  analytical  methods,  nor  a  description  of  the
computation used  for its determination, the  applicant should be
requested to provide this  information or provide the information
necessary to perform the computation.  If this occurs,  the reviewer
may calculate the LLD using the information provided.

Detection  limits  may  be expressed  as  a   "minimum detectable
activity"  (MDA)  or  "minimum  detectable  concentration"   (MDC).
Calculating the MDA or MDC requires determination of  the standard
deviation of the  background  count rate  (Sb) .   This  value can be
used in the above equation to compute the MDA or MDC.

The following EPA document provides more details on the basis and
derivation of the LLD: Upgrading Environmental Radiation Data, EPA
520/1-80-012, pp.6-14 to 6-34, August 1980.


                                40

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Table  6-2  lists  typical  sensitivities  and  examples of  actual
procedural  sensitivities  for  some  of  the  major  radionuclides
released by DOE facilities.  The  required  sensitivities  are one-
tenth the concentrations listed in 40 CFR 61, Appendix E,  Table 2.
The  procedural sensitivities  are  based  primarily  on  airborne
radionuclide measurement  program  results conducted at the EPA's
National  Air  and  Radiation   Environmental  Laboratory  (NAREL),
formerly  the  Eastern  Environmental  Radiation  Facility  (EERF)
(BROS3).    The  information in  Table   6-2  indicates  that  the
sensitivities for  measuring all particulate  radionuclides, tritium,
and carbon-14 are  quite  adequate to satisfy  the requirements of the
rule.  On the other hand,  the sensitivities associated with argon-
41 and krypton-88, are not low  enough to  satisfy the sensitivities
required by the rule.

6.3.5  Radionuclide concentrations that would cause an effective
       dose equivalent of 1 mrem/yr must be  readily distinguishable
       from background:  How should this be determined?

The background radionuclides concentrations are typically low such
that nearly all nuclides released  by DOE  facilities can be readily
distinguished from background levels at concentrations that would
cause an effective  dose equivalent of  1  mrem/yr (see Table 6-2).
However, there are two notable exceptions,  radon-222 and external
exposure rates:

     1)   radon-22  concentrations  in air that  cause an effective
          dose  equivalent to  the  lung  of  1  mrem/yr cannot  be
          distinguished from a background concentration of less 0.5
          pCi/L; and

     2)   submersion dose rates of  1 mrem/yr caused by radionuclide
          concentrations   in  air   cannot  be distinguished  from
          background external exposure rates due to photons.

Therefore, any DOE applications proposing to measure radon-222 or
external  exposure rates  should be  carefully  evaluated  for its
technical merits.
                                41

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Table 6-2  Examples of Backgrounds and Sensitivities of Some
           Principal Airborne Radionuclides Released from DOE
           Facilities
                 Required        Representative          Example
Radionuclide   Sensitivity'13       Background          Sensitivity


                         Concentration (aCi/m3)
     U-234
     U-238
     Pu-238
     Pu-239
     Am-241
770
830
210
200
190
25(2>
25<2>
<4(2)
<4(2>
<4
13<3)
13(3)
13(3)
13(3)
13(3)
                         Concentration (pCi/m3)
     Ar-41
     Kr-85
     Kr-88
     C-14
     H-3
170
100,000
50
NL<7>
150
0
40<5>
0
1.3<8)
<1.1(9>
600<4>
ND(&)
ND
1-1
<1.1
(1)  These sensitivities are 1/10 the concentrations listed in 40
     CFR 61, Appendix E, Table 2.
(2)  Average of January - December 1986 airborne measurements in 63
     U.S. cities (EERF87a, b).
(3)  Based on a weekly sample, average collection rate of 26 cfm,
     analysis of 1/2 filter,  and a measurement  sensitivity of 0.05
     pCi/sample.
(4)  Estimated from an EPA report on airborne radionuclides at the
     Savannah River Plant  (BLA84).
(5)  Average concentration measured in air at 12  U.S.  cities in
     1983,  Environmental  Radiation  Data  (ERD)   filed,  Eastern
     Environmental Radiation Facility, EPA.
(6)  ND - Not Determined.
(7)  NL - Not Listed.
(8)  Concentration taken from pp. 61-62 of NCRP85 and ORP73.  This
     concentration relates to 7.5 pCi/g carbon.
(9)  This  estimate  assumes  30  percent humidity  at 20  °C  and a
     background <200 pCi/L of water vapor.
                                42

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Background  levels are  defined as  general ambient  radionuclide
concentrations that are not related to an emission source.  In some
cases, sources other than the facility of interest may contribute
to  the  radionuclide  concentrations  at  the  critical  receptor
location.   Uranium mining and milling facilities are  potential
examples  of   multiple  emission  source  contributing   to  the
measurements  made at  a single  receptor location.   Also,  this
situation can exist when several different  facilities  releasing
similar contaminants are in the same area.  In these cases, it may
be difficult to distinguish individually the contributions of the
various sources at receptor locations.

Similarly, when  the radionuclide being monitored  also  occurs in
nature   (e.g.,   potassium-40),  the  contribution   to   airborne
concentrations from natural sources during high-wind conditions may
not be distinguishable  from the amount of the radionuclide released
from the facility.  Therefore, because of these uncertainties, no
correction  (subtraction)  of  concentrations resulting  from other
sources  to  the concentration  measured  at the  receptor location
should   be   allowed  (i.e.,   the  total   measured  radionuclide
concentration shall be used to determine compliance).

Monitoring programs that include subtractions from other emission
sources should be critically reviewed as the proposed method may be
technically  incorrect.  Rather, the total  airborne concentration
(from all sources) should be compared to the concentration levels
of Table 2,  Appendix E of 40 CFR 61,  to determine compliance.

6.4  Quality  Assurance Program  in Response  to  the  Performance
     Requirements of Appendix B, Method 114, 40 CFR 61:
     How is the validity of a QA Program evaluated?

The application should  include a  statement that the applicant is
conducting or is  in the process of developing a quality assurance
(QA) program in general conformance with the requirements of Method
114.   Specifically,  the  applicant should provide the information
required by Section 4 of Method 114,  including the following:

     1)   the   requirements   for   precision,   accuracy,   and
          completeness of the environmental measurements; and

     2)   the number of replicates, spiked samples, split samples,
          and blank samples to be analyzed.

Applications  that do not  indicate the conduct of a QA program in
conformance  to the requirements  of Method  114  should not be
approved. A certain degree of technical judgment may be allowed in
judging whether  a QA program is  in conformance with Method 114.
Quality assurance programs that meet the general intent of Method
114 should be judged to be in conformance, when properly justified
and documented.
                                43

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If any  information required by  Section 4  of  Method 114  is  not
available, the applicant should be informed that this information
must be provided.  In reviewing these requirements, the following
guidelines should be used:

     1)    the accuracy and precision  of the measurements should be
          within 20 percent at the concentration levels listed in
          Table 2 of Appendix E;

     2)    completeness should be at least 95 percent, that is, 95
          percent of  the samples collected should provide valid
          data; and

     3)    20 percent of the sample analyzed should be replicates,
          blank, split, or spiked samples.  Usually 10 percent are
          duplicate or split samples,  5 percent are blank samples,
          and 5 percent are spiked samples.
                                44

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                            Chapter 7

           GUIDANCE ON METHODS FOR ESTIMATING FUGITIVE
                    RADIONUCLIDE AIR  EMISSIONS

7.1  Estimation of Radionuclide Emissions Using Fugitive Dust
     Emission Models

Chapters 3 and 4 of this report present a number of fugitive dust
emission models which are described  in  EPA guidance documents or
have  been endorsed  by  the  EPA  by  way  of other  EPA-sponsored
publications.  To  use these models  for  calculating the fugitive
emissions of radionuclides,  it is necessary to characterize the
radionuclide concentrations in the emitted dust.

Two measures commonly used to characterize the soil contamination
- the specific activity  (pCi/g) of the bulk material  in situ or the
surface  concentration  (pCi/m2)  -  are  not satisfactory  for this
purpose.  The bulk  specific activity method will lead to errors for
two reasons.

•    First,  radioactive contamination  is  not always  uniformly
     distributed in the soil  layer.   If the contamination had been
     deposited on the ground from an atmospheric plume  or cloud, it
     will initially be concentrated on the surface.   After a period
     of weathering, the  activity in the underlying soil layers will
     increase, while decreasing at the surface.  However, the fine
     soil or  dust  particles  available  for resuspension typically
     reside in a one millimeter-thick layer on  the surface.  Thus,
     the average specific activity in,  say, the top six inches of
     the  soil (the  layer  which  is  generally sampled)  will  not
     generally be representative of the suspensible  soil fraction.

•    Second,  as  Langer  found  at  Rocky Flats,  specific activity
     varies  with  particle  size  (LAN83).    The  fugitive  dust,
     consisting predominantly of fine particles, will have a size
     distribution very different from that of the particles in the
     soil layer.   Therefore,  even  if  the bulk specific activity of
     the sampled soil layer did not vary with depth, this activity
     will generally be different from the  specific activity of the
     resuspended particles.

Surface  concentrations  are usually calculated by  determining the
total activity of a given soil sample and then dividing by the area
of the  sampled surface.   They are thus a  measure  of the average
activity over the  depth of  the sample.  The use of such a value
leads to the same errors  in estimating the activity of  the fugitive
dust as does the use of the bulk specific activity.
                                45

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A  more  acceptable method  involves  collecting  samples  of  the
suspensible fraction from the surface of the contaminated area and
determining the  specific activity (pCi/g of dry  weight)  of each
radionuclide.  A simple method of  accomplishing this is to collect
that portion  of  the surface soil that passes through  a  200 mesh
screen  upon  dry  sieving (EPA85a,  p. 17).   More  sophisticated
sampling devices,  such  as a  dust  collector may  also be used.  One
drawback  of  these techniques  is  that  the  process  of  sample
collection may distort the distribution of radionuclides among the
variously  sized  particles.    Another  is that  samples  may  be
collected   from   a deeper   soil   layer   than  actually  becomes
resuspended.   If  the  contamination had  originally been deposited
from the atmosphere,  it will  tend to be  more  concentrated on the
surface.   Collecting  subsurface dust will dilute the  sample and
will usually  lead  to an underestimate of the emissions.

A still better method involves the use of portable wind tunnels to
suspend the dust and collect samples.  There is some controversy,
however, as to whether such sub-scale testing develops a flow field
that is indicative of what it would be in the atmospheric boundary
layer.  The MRI is  currently preparing to carry out such studies at
the Rocky Flats site.   From a theoretical standpoint,  the best
method  is   to measure  the   specific activity  of the  particles
collected by  ambient  air samplers.  An overview of environmental
monitoring is presented in Chapter 6.

The  annual   effluent   radionuclide  activity  is  calculated  by
multiplying the predicted annual emission  of TSP from a particular
source  by  the  specific activity of each  radionuclide  in that
source.

7.2  Calculating Effluent Releases From Sampling Data

7.2.1  Calculation of gaseous releases at NTS

Effluent releases from both  drillback systems at NTS, discussed in
para.  5.3.1,  could be  determined by a  variant  of the  exposure
profiling  method  employed  by  MRI  to  measure  fugitive  dust
emissions,   with   air  samplers  designed  to   collect  gaseous
radionuclides  being  substituted  for  the  ones used to  trap dust
particles.     Such  a  method would  quantitatively  intercept  the
effluent plume and not be  dependent on  atmospheric  dispersion
calculations, which are  of questionable validity  at short distances
from the source,  nor on the  current validity of historical data on
effluent emissions and radioactivity measurements.  An alternative
method  would  be  to  attempt  to pinpoint  the  source  of  the
uncontrolled  emissions  and  to measure both the  activity  and the
volumetric release rate of the effluent gases from that point.  Not
enough information about the  drillback  operation is available to
enable us to determine if the latter procedure  is feasible.  Either
of  these  proposed methods  would  yield  more  accurate  release
estimates than the ones currently employed.

                                46

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Releases  due to  the  ground seepage  of noble  gases  at NTS  are
estimated  by collecting  downwind air  samples at  two or  three
locations  and  using  the  CAP88-PC  code  to  back-calculate  the
emission rate.  Although the samples are collected over periods of
one week, historical annual-average meteorological data are used
as  input for  the code.   This  approach  might present  specific
problems  in  assessing  its  inherent  variability  and degree  of
conservatism, if any.

Other methods  of  quantifying effluent concentrations  include the
use  existing  environmental  monitoring  stations  at  appropriate
locations and in a sufficient numbers to intercept the plume over
its entire cross-section.  The other method involves the use of a
combination of upwind and downwind air samplers,  including at least
two  downwind  distances,   along  with concurrent  wind  velocity
measurements and stability class determinations.

An overview of environmental monitoring is presented in Chapter 6
in the context of  demonstrating compliance with Subpart H of 40 CFR
61.

7.2.2  Critique of methods used at other DOE sites

The preceding critique of the methods  used  to estimate releases of
radionuclides  at  NTS  applies to  other DOE sites  where  effluent
emissions from  area sources,  whether  gaseous  or particulate, are
estimated  on the  basis of  downwind  or  perimeter air  samples.
Several  sites report using  the  EPA  model CAP88-PC  to  estimate
releases.

There are a  number of drawbacks to using the  computer code CAPS8
for this  purpose.   This model was developed  for  calculating the
annual  effective  dose  equivalent to  the  population  and  to the
maximally exposed individual.  Known or estimated release rates are
input to the model along with annual-average meteorological data.
The  model  then calculates  radionuclide  concentrations  at  the
receptor site and uses the appropriate dose conversion factors to
calculate the effective dose equivalent.

One obvious source of error in using CAP88  to calculate the source
term is the possible use of a different dose conversion factor than
one used  by the code.  (Such  an error may have occurred  at NTS,
where  a  dose  factor  cited in  a  DOE  document  has been  used to
calculate a dose from a measured concentration.  This dose was then
compared to a CAP88-calculated dose equivalent).

A more  fundamental error  may result  from the use of annually-
averaged meteorological data to  calculate short-term, time-varying
releases. Samples are collected over weekly or monthly periods, and
annually-averaged  meteorological  data   does  not   accurately
characterize  such a-  short collection  period.   Another  problem
results in the calculation  of sector-averaged atmospheric dilution

                                47

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factors.  According to the Guideline on Air Quality Models (EPA86,
p.  8-6) ,  sector averaging is "acceptable only  to  determine long
term averages."  While  this  model  assumption  is valid for annual
dose calculations, errors  can occur if  it  is  used  for short-term
calculations.
Perhaps  the   most  significant  criticism  of   using  measured
concentrations and CAP88 to calculate emissions is that  it begs the
question that this study was  designed  to  answer.   The  purpose of
calculating  emissions  is  to provide  the  EPA with a basis  of "7
calculating  risks to the  public other  than that provided  by
measured  off-site  radionuclide  concentrations.    If  the  same °
concentration measurements, the  same meteorological data  and the
same model are used to calculate both the dose and  the source term,
no  new  information   is  gained;   the  calculations  are merely  a
numerical exercise.

7.2.3  Estimating  fugitive particulate emissions from environmental   ,
       sampling and monitoring                             .^  ^ -fW

A case might be made that by using the results of environmental
sampling and monitoring, fugitive emissions,  in  effect,  could be
derived by applying an atmospheric dispersion factor to the field
data.   However,  the EPA  has  not analyzed  this  approach,  and
therefore  it  cannot  be  recommended   for   this  purpose.    The
development  of such  a   model  requires that complex   factors  be
considered, including, among others:

•    validation of the deployment scheme, locations,  and numbers of
     environmental sampling stations.

•    validation of the selected sampling and  analytical methods for
     the expected radionuclides.

•    representativeness of the field  data  to  the emission sources.

•    atmospheric behavior of contaminants while in transient from
     the source of emission to the sampling station.

•    atmospheric dispersion and concurrent meteorological data for
     the site.

•    site  specific   features   (e.g.,   terrain,   ground   cover,
     obstructions, control measures to mitigate releases,  etc.).

•    radiological, physical,  and chemical characteristics of the
     contaminants.

     physical characteristics of emission  sources  and temporal and
     spatial distributions of emission rates.
                                48

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7.3  Summary of Guidance and Methods

A  summary  of the methods  to estimate fugitive  emissions,  water
vapor, and  radioactive  gaseous effluents is given  in  Table 7-1.
For each release mechanism, the methodology for estimating emission
rates is tabulated,  along with the current status  of the procedure.
Procedures included in AP-42 are for the purpose  of estimating the
emission of  air  pollutants.   Other procedures  appear  in  an EPA
guidance document  on particulate  emissions from TSDF (EPA89a).
Still others are  from EPA,  NRC,  and  DOE documents used for various
applications (EPA88a, DOE93, NRC92).

In cases of  release mechanisms for which no  EPA-approved models
exist, alternative methods used by the NRC, DOE, or the MRI  (an EPA
contractor)  may  be  proposed,  given  that  they  are  technically
justified and fully documented.

To estimate the effluent radionuclide activities, it is necessary
to combine the procedures in  Table  7-1 with  the sampling and
calculational methods described in this report.
                                49

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Table 7-1 SUMMARY OF METHODS FOR ESTIMATING FUGITIVE EMISSIONS
Mechanism
WIND EROSION
Open areas
Limited
Unlimited
Waste piles
Intermittent
Continuous
Uranium ore &
mill tailings
MATERIAL HANDLING
Soil removal
Soil grading &
shaping
Agriculture
Demolition
UNPAVED ROADS
EVAPORATION
Open ponds
Soil
Saturated
Subsurface
GASEOUS (NTS)
Procedure
AP-42 method using "fastest mile"
Modified Wind Erosion Equation
AP-42 method using "fastest mile",
modified for geometry of pile
AP-42 aggregate handling emission
factor
NRC Regulatory Guide 3.59 methodology
Same as continuous waste piles
AP-42 emission factor for bulldozing
overburden at Western coal mines
AP-42 emission factor
Same as continuous waste piles
AP-42 methodology
Evaporation equation from NUREG-0570
Same as open ponds
Superfund Exposure Assessment Manual
Proposed air sampling protocol
combined with short-term site-
specific dispersion calculations
Status
Adopted by EPA (AP-42)
Approved by EPA (EPA88a)
Adopted by EPA (AP-42)
Adopted by EPA (AP-42)
Adopted by EPA
EPA guidance for TSDF
EPA guidance for TSDF
Adopted by EPA (AP-42)
Approved by EPA (EPA88a)
Adopted by EPA (AP-42)
Used by NRC Staff
Based on EPA88c
EPA: OSWER Directive
Proposed
50

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    Table 7-1  SUMMARY OF METHODS FOR ESTIMATING FUGITIVE EMISSIONS, Cont'd
   Mechanism
              Procedure
        Status
EQUIPMENT &
FACILITIES
 Buildings

 Tank venting
 Equipment
 Wet-cooling
 tower
Proposed method based on measurement
or estimated source term
Same as above
Same as above
Same as PM10 particulates
Proposed

Proposed
Proposed
Proposed
CONTAMINATED
SOILS
  Tritium
  Carbon-14
Proposed based on DOE model
Proposed based on DOE model
Proposed
Proposed
                                          51

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8.0   REFERENCES

BLA84     Blanchard, R.L., Broadway, J.A. and Sensintaffar, E.L.,
          "An Airborne Radioactive Effluent Study at the Savannah
          River  Plant,"  U.S.  Environmental  Protection  Agency
          Report, EPA 520/5-84-012, June 1984.

BR083     Broadway, J.A.,  and Mardis, M.,  "Analytical Capability of
          the Environmental Radiation Ambient Monitoring System,"
          U.S. Environmental Protection Agency Report, EPA 520/5-
          83-024, September 1983.

BUR89     Burkhard, N.R., et al, 1989. "Containment of Cavity Gas
          in Fractured or Rubblized Emplacement Media."  Presented
          at the 5th  Symposium  on  the Containment of Underground
          Nuclear  Detonations,  Santa  Barbara,  CA, Sept.  19-21,
          1989.

DOA88     U.S. Department of Agriculture,  1988.  National Agronomy
          Manual,  2nd  ed.,  (Parts 500-509).  U.S.  Department of
          Agriculture, Soil Conservation  Service, Washington, D.C.

DOE84     Randerson, D.,  ed.,  1984. Atmospheric Science and Power
          Production.  U.S.   Department   of  Energy,   Office  of
          Scientific   and   Technical   Information,    Technical
          Information Center,  Oak Ridge,  TN.

DOE86     Langer,  G. ,  1986.    Dust  Transport -  Wind  Blown and
          Mechanical  Resuspension, July  1983 to  December 1984.
          Rockwell International, Energy Systems Group, Rocky Flats
          Plant, Golden, CO.

DOE92     Black, S.C., and W^G.  Phillips,  1992.  National Emission
          Standards for Hazardous  Air Pollutants Submittal-1992.
          Reynolds Electrical & Engineering Co., Inc., Las Vegas,
          NV.

DOE92a    Integrated  Database  for  1992:   U.S.  Spent  Fuel  and
          Radioactive   Waste   Inventories,   Projections,   and
          Characteristics,   DOE/RW-0006, Rev. 8.,  Department of
          Energy, Office of Civilian Radioactive Waste Management,
          Oak Ridge, TN, October 1992.

DOE93     U.S.  Department  of  Energy,   Manual  for   Implementing
          Residual Radioactive materials Guidelines Using RESRAD,
          Ver.  5.0,  Argonne  National  Laboratory,   Argonne  IL,
          September 1993.

DOE94     Summary of Radionuclide Air  Emissions from Department of
          Energy Facilities for  CY 1992, DOE/EH-0360, Department of
          Energy, Office of Environmental Guidance, Washington, DC,
          February 1994.

                                52

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EERF87a   Eastern Environmental Radiation Facility, "Environmental
          Radiation Data: Report 47, "U.S. Environmental Protection
          Agency Report, EPA 520/5-87-006,  June 1987.

EERF87b   Eastern Environmental Radiation Facility, "Environmental
          Radiation Data: Report 48, "U.S. Environmental Protection
          Agency Report, EPA 520/5-87-017,  June 1987

EPA83     Dynamac Corp., 1983.  Methods for Assessing Exposure to
          Windblown   Particulates,   EPA-600/4-83-007.      U.S.
          Environmental Protection Agency,  Office of  Health and
          Environmental Assessment, Washington, D.C.

EPA85a    Cowherd,  C.,  G.E.  Muleski,  P.J.  Englehart,  and  D.A.
          Gillette,  1985.   Rapid  Assessment  of   Exposure  to
          Particulate Emissions from Surface Contamination Sites,
          EPA/600/8-85/002. U.S.Environmental  Protection Agency,
          Office   of   Health  and  Environmental   Assessment,
          Washington, D.C.

EPA85b    U.S. Environmental Protection Agency,  1985.  Compilation
          of Air Pollutant  Emission Factors, vol. 1, AP-42, 4th Ed.
          U.S.  Environmental  Protection Agency;  Office  of  Air,
          Noise and Radiation; Office of Air Quality Planning and
          Standards; Research Triangle Park, NC.

EPA86     U.S. Environmental Protection Agency, 1986. Guideline on
          Air   Quality    Models,    EPA-450/2-78-027R.       U.S.
          Environmental Protection Agency,  Office of Air Quality
          Planning and Standards,  Research Triangle Park, NC.

EPA88a    Cowherd,  C.,   G.E.   Muleski,  and J.S.  Kinsey,  1988.
          Control of Open  Fugitive Dust Sources, EPA-450/3-88-008.
          U.S.  Environmental   Protection  Agency,  Office of  Air
          Quality Planning and Standards,  Research Triangle Park,
          NC.

EPA88b    Joyner,  W.M.,  1988.    Compilation   of Air  Pollutant
          Emission  Factors,  vol.   1:   Stationary Point  and  Area
          Sources,   4th   ed.   Supplement   B,   AP-42-SUPPL-B,
          Environmental Protection Agency,  Office of Air Quality
          Planning and Standards,  Research Triangle Park, NC.

EPA88c    U.S.  Environmental  Protection Agency,  1988.   Superfund
          Exposure Assessment Manual, U.S. Environmental Protection
          Agency, Office of Remedial Response, Washington, D.C.
                                53

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EPA89a    Cowherd,  C.,  P.  Englehart,  G. E.  Muleski,  and  J.  S.
          Kinsey,  1989.Hazardous  Waste  TSDF (Treatment,  Storage,
          and Disposal Facilities) : Fugitive Particulate Matter Air
          Emissions  Guidance Document,  EPA-450/3-89/019.    U.S.
          Environmental Protection Agency,  Office  of Air Quality
          Planning and Standards, Research Triangle Park, NC.

EPA89b    U.S. Environmental Protection Agency,  1989.   40 CFR Part
          61:    National  Emission  Standards  for  Hazardous  Air
          Pollutants;  Radionuclides;  Final  Rule  and Notice  of
          Reconsideration, Federal Register, Part II, Vol. 54, No.
          240, December 15, 1989.

EPA89c    Environmental Protection Agency, "Background  Information
          Document - Volumes 1 and 2, NESHAPS for Radionuclides,"
          US Environmental Protection Agency Report, EPA 520/1-89-
          006-2, September 1989.

EPA90     Joyner,  W.M.,   1990.     Compilation  of  Air Pollutant
          Emission  Factors,  vol. 1:   Stationary  Point  and Area
          Sources,   4th   ed.   Supplement   C,   AP-42-SUPPL-C,
          Environmental Protection Agency,  Office  of Air Quality
          Planning and Standards, Research Triangle Park, NC.

EPA91     Joyner,  W.M.,   1991.     Compilation  of  Air Pollutant
          Emission  Factors,  vol. 1:   Stationary  Point  and Area
          Sources,   4th   ed.,    Supplement  D,   AP-42-SUPPL-D,
          Environmental Protection Agency,  Office  of Air Quality
          Planning and Standards, Research Triangle Park, NC.

EPA92     Environmental Protection Agency, 1989. Characterization
          Protocol For Radioactive  Contaminated Soils, Office of
          Solid Waste and Emergency Response, Office of Emergency
          and Remedial Response,  and Office  of Radiation Programs,
          Publication 9380.1-10FS, May 1992, Washington, DC.

EPA93a    Environmental   Protection   Agency,   1993.   Draft  Soil
          Screening Level Guidance,   Quick  Reference  Fact Sheet,
          Office of Solid Waste and Emergency Response, Office of
          Emergency  and   Remedial  Response,  and  Hazardous Site
          Control Division, September 29, 1993, Washington, DC.

EPA93b    Environmental Protection Agency, 1993. Evaluation  of the
          Dispersion  Equations  in  the  Risk  Assessment  Guidance
          Document for Superfund  (RAGS): Volume I  - Human Health
          Evaluation Manual  (Part  B) ,  Development  of  Preliminary
          Remediation Goals),  Office  of Emergency  and  Remedial
          Response  and Toxics  Integration  Branch,  April  1993,
          Washington, DC.
                                54

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GIL83a    Gillette,  D.A.,  1983.   "Threshold  Velocities  for Wind
          Erosion  on  Natural  Terrestrial  Arid    Surfaces   (A
          Summary)", in Precipitation Scavenging, Dry Deposition,
          and   Resuspension:     Proceedings   of   the   Fourth
          International Conference,  Santa  Monica,  California,  29
          November - 3 December 1982, vol. 2, H. R. Pruppacher et
          al., eds., Elsevier, New York.

GIL83b    Gillette, D.A., and C. Cowherd, 1983.  " The Concept of
          Resuspension Rates Applied to Problems of Fugitive Dust
          Emissions and Wind Erosion" in Precipitation Scavenging,
          Dry  Deposition,  and  Resuspension:  Proceedings  of the
          Fourth    International    Conference,    Santa   Monica,
          California, 29 November -  3 December 1982, vol. 2, H. R.
          Pruppacher et al., eds., Elsevier, New York.

KIN92     Kinsey, J. S., 1992.  Private communication.

LAN83     Langer,  G.,  1983.     "Activity,   Size  and  Flux  of
          Resuspended   Particles   From  Rocky   Flats   Soil"  in
          Precipitation    Scavenging,    Dry    Deposition,    and
          Resuspension:  Proceedings of  the Fourth International
          Conference,  Santa  Monica,  California, 29 November - 3
          December  1982,  vol. 2, H.R.  Pruppacher et  al.,  eds.,
          Elsevier, New York.

LANL92    Henderson, R.W., 1992 (Unpublished).   "Operational Area
          Monitoring Plan  for the Los Alamos National Laboratory
          Testing Area and Facilities, Nevada Test Site".

LEE90     Leeden,  F.,  Troise,  F.,  and  Todd,  D.,  The  Water
          Encyclopedia, Lewis Publishers,  2nd  Ed.,  Chelsea, MI,
          1990.

NCRP85    National   Council    on   Radiation   Protection   and
          Measurements, "Carbon-14 in the Environment," NCRP Report
          No. 81, May 15, 1985.

NCRP79    National   Council    on   Radiation   Protection   and
          Measurements, "Tritium in  the Environment," NCRP Report
          No. 62, March 9, 1979.

NIC88     Nicholson,   K.W.,   1988.      "A  Review   of  Particle
          Resuspension." Atmospheric Environment, 22, 2639-2651.

NIC90     Nicholson,  K.W.,  and  J.R.   Branso,   1990.    "Factors
          Affecting  Resuspension  by  Road Traffic."  The Science of
          the Total Environment, 93, 349-358.

NIE90     Nielsen, S.P., et al.,  1990.   "Dry Deposition of MRb and
          137Cs From a- Boiling Water Reactor Plume." Health Physics
          58, 283-289.

                                55

-------
NIL	     Nilson, R.H., et al.  (Unpublished).  "Field Measurements
          of Gas Transport Induced by Atmospheric Pumping".

NIL91     Nilson, R.H.,  et al.,  1991.   "Atmospheric  Pumping:   A
          Mechanism  Causing Vertical  Transport  of  Contaminated
          Gases  Through Fractured  Permeable  Media."  Journal  of
          Geophysical Research, 96, 21.933-21.948.

NRC79     Wing,  J.,   1979.   Toxic Vapor  Concentrations  in  the
          Control Room Following a Postulated Accidental Release,
          NUREG-0570.  U.S. Nuclear Regulatory Commission, Office
          of Nuclear  Reactor Regulation,  Division of Site Safety
          and Environmental Analysis, Washington, D.C.

NRC83     U.S.   Nuclear   Regulatory  Commission.   Radiological
          Assessment, NUREG/CR-3332, Nuclear Regulatory Commission,
          Office of Nuclear Regulatory Research, Washington, D.C.,
          September 1983.

NRC87     U.S.  Nuclear Regulatory Commission,  1987.   Regulatory
          Guide 3.59:Methods for Estimating Radioactive and Toxic
          Airborne Source  Terms for  Uranium  Milling Operations.
          U.S.  Nuclear Regulatory Commission,  Office of Nuclear
          Regulatory Research,  Washington, D.C.

NRC92     U.S. Nuclear Regulatory Commission. Residual Radioactive
          Contamination  from  Decommissioning:  Vol.  1, Technical
          Basis  for  Translating  Contamination Levels  to Annual
          Total Effective Dose Equivalent, NUREG/CR-5512, Nuclear
          Regulatory  Commission,  Office  of  Nuclear Regulatory
          Research, Washington, D.C., September 1992.

ORP73     Office of Radiation Programs,.US Environmental Protection
          Agency, "Carbon-14 in  Total Diet and Milk,  1972-1973,"
          Radiation Health Data Reports 14. 679, November 1973.
                                56

-------
ORNL92    Yuan,   Y.C.,   J.H.C.  Wang,   and  A.   Zielen,   1992.
          MILDOS-AREA:    An   Enhanced   Version  of  MILDOS  for
          Large-Area  Sources.    Oak  Ridge National  Laboratory,
          Radiation Shielding Information Center, Oak Ridge, TN.

PET91     Pettersson,    H.B.L.,    and    J.    Koperski,    1991.
          "Investigation of Aerial Dispersion of Radioactive Dust
          from  an   Open-Pit   Uranium  Mine  by  Passive  Vinyl
          Collectors."  Health Physics 60, 681-690.

PIN90     Finder,  J.E.,  et  al.,  1990.   "Atmospheric Deposition,
          Resuspension, and Root  Uptake of Pu  in  Corn and Other
          Grain-Producing  Agroecosystems  Near  a  Nuclear  Fuel
          Facility".  Health Physics, 59, 853-867.

PRU83     Pruppacher,  H.R.,  et al.,  eds., 1983.   Precipitation
          Scavenging,    Dry    Deposition,    and   Resuspension:
          Proceedings of the Fourth International Conference, Santa
          Monica,  California,  29  November  -  3   December  1982,  2
          vols.  Elsevier, New York.

PYE87     Pye, K., 1987.  Aeolian, dust and dust deposits.  Academic
          Press, New York.

REE88     Reeks,  M.W.,  J.  Reed,   and D.  Hall, 1988.    "On  the
          Resuspension of Small  Particles by a Turbulent Flow."
          Journal of Physics D:  Applied Physics, 21, 574-589.

SEH80     Sehmel,    G.A.,    Particle  Resuspension:   A   Review,
          Environmental International, Vol. 4, pp.107-127, 1980.

SMI82     Smith, W.J., F.W.  Whicker and  H.R. Meyer,  1982.  "Review
          and   Categorization   of   Saltation,    Suspension  and
          Resuspension Models". Nuclear Safety 23(6).

SMI83     Smith,  W.J.,  and  F.W.  Whicker,  1983.   "Quantitative
          Comparison of Five Suspension Models", in Precipitation
          Scavenging,    Dry    Deposition,    and   Resuspension:
          Proceedings of the Fourth International Conference, Santa
          Monica,  California, 29 November - 3 December 1982, vol.
          2, H.R.  Pruppacher et al.,  eds., Elsevier, New York.
                                57

-------
                        Attachment 1
Excerpts from Control of Open Fugitive Dust Sources (EPASSa)
                             61

-------
                                          PB89-103691

                                           EPA-450/3-88-008
    CONTROL OF OPEN FUGITIVE OUST SOURCES
                FINAL REPORT
                     by

 C. Cowherd,  6.  E.  Muleskl. tnd J. S. Klnsey
         Midwest Research Institute
            425 Volker Boulevard
        Kansas City. Missouri  64110
         EPA Contract No.- 68-02-4395
             Work Assignment 14
             MRI  Project 8985-14
     Hllllan L. Elaore, Project Officer
         Emission  Standards  Division

Office of Air Quality Planning and Standards
    U.  S.  Environmental  Protection Agency
   Research Triangle Park, North Carolina
               September 1988
                                	
             US. DEPARTMENT OF COMMERCE
                  NATDNM.TECHMCAL
                  tFORMATDNSEfMCC
                  SPRMGFELD.VA221I1

-------
      1.   Loading of aggregate onto storage piles (batch or continuous  droo
 operations).
      2.   Equipment traffic tn storage area.
      3.   Wind erosion of pile surfaces and ground areas around piles.
      4.   Loadout of aggregate for shipment or for return to the process
 strew (batch or continuous drop operations).
 4.1.1 Materials Handling
    .Adding aggregate material to a storage pile or removing It usually
 Involves  dropping the material onto a receiving surface.   Truck dumping on
 the pile  or loading out fron the pile to a truck with  a front-end loader
 •re examples of batch drop operations.  Adding material  to the pile by a
 conveyor  stacker Is in example of a continuous drop operation.
      The  following equation Is recomnended for estimating  emissions from
 transfer  operations (batch or'continuous drop):
                    E - k(0.0016) *•« A>4  (kg/Mg)

                                                                    (4-1)

                                 (U)  ^    '
                    E • k(0.0032) 5  .  ,  (Ib/ton)
                                 <&^
where:  E • emission factor
        k • particle size multiplier  (dimensionless)
        U • mean wind speed, m/s  (mph)
        M • material moisture content,  percent
The particle size multiplier k varies with  aerodynamic particle diameter
as shown below:
                  Aerodynamic  Particle Size Multiplier, k
     <30 um .       <15 um        <10  -ja       <5 um
                                                               fl.ll
Based on the criteria presented  1n AP-42, the above equation 1s rated A.
                                 J-3

-------
      For emissions  from  equipment  traffic  (trucks,  front-end  loaders,
 dozers, etc.) traveling  between or on piles.  It 1s  recommended  that  the
 equations for vehicle traffic on unpaved surfaces be used  (see
 Section 3-0).  For  vehicle travel  between  storage piles, the  silt  value(s)
 for the areas among the  piles (which may differ fron the silt values for
 the stored materials) should be used.
 4.1.2 Wind Erosion
      Oust emissions may  be generated by wind erosion of open  aggregate
 storage piles and exposed areas within an  Industrial facility.  These
 sources typically art characterized by nonhonogeneous surfaces  Impregnated
 with  nonerodlble elements (particles larger than approximately  1 cm  1n
 diameter).  Field testing of coal  piles and other exposed materials  using
 a portable wind tunnel has shown that (a) threshold wind speeds exceed
 5 m/s (11 mph) at 15 cm  above the  surface or 10 m/s (22 mph)  at 7 •  above
 the surface, and (b) part1culate emission rates tend to decay rapidly
 (half life of a few minutes) during an erosion  event.  In other words,
 these aggregate material surfaces  are characterized by finite availability
 of credible material (mass/area) referred to as the erosion potential.
 Any natural crusting of  the surface binds the credible material, thereby
 reducing the erosion potential.
      4.1.2.1  Emissions  and Correction Parameters.  If typical values for
 threshold wind speed at  15 cm are  corrected to  typical wind sensor height
 (7-10 m), the resulting  values exceed the upper extremes of hourly mean
 wind  speeds observed 1n most areas of the country.  In other words,  mean
 atmospheric wind speeds  are not sufficient to sustain wind erosion from
 aggregate material  surfaces.  However, wind gusts may quickly deplete a
 substantial portion of the erosion potential.   Because erosion potential
 has been -found to Increase rapidly with Increasing wind speed, estimated
 emissions should be related to the gusts of highest magnitude.
      The routinely measured meteorological variable which best reflects
 the magnitude of wind gusts 1s the fastest mile.  This quantity represents
 the wind speed corresponding to the whole mile  of wind movement which has
 passed by the l-m1 contact anemometer 1n the least amount of time.   Daily
measurements of the fastest mile are presented  in the monthly Local
 CUmatologlcal Data (LCD) summaries.  The LCD summaries can be obtained
                                  4-4

-------
 from the National Climatic Center, Ashevllle. North Carolina.  The
 duration of the fastest mile, t^lcally about 2 *1n (for a fastest «lle of
 30 «ph), matches well with the  half  life of the erosion process, which
 ranges between 1 and 4 »1n.  It should be noted, however, that peak winds
 can  significantly exceed the dally fastest mile.
      The wind speed profile In  the surface boundary layer 1s found to
 follow a logarithmic distribution:
                        u(2)  - £y ln(|-)   (2  > 20)                   (4-2)
                                      o
 where:    u • wind speed, cm/s
         u* • friction velocity* a/s
          2 • height above test surface, or
         ZP • roughness height, em
        0.4 • von (Carman's constant, dlaenslonless
      The friction velocity (u*) Is a measure of wind shear stress on the
 credible surface, as determined from the slope of the logarithmic velocity
 profile.  The roughness height  (z0) 1s a measure of the roughness of the
 exposed surface as determined from the y-Intercept of the velocity
 profile. I.e., the height at which the wind speed 1s zero.  These
 parameters are Illustrated 1n Figure 4-1 for a roughness height of 0.1 cm.
      Emissions generated by wind erosion are also dependent on the
 frequency of disturbance of the credible surface because each time that a
 surface 1s disturbed. Us erosion potential 1s restored.  A disturbance 1s
 defined as an action which results In the exposure of fresh surface
material.  On a storage pile, this would occur whenever aggregate material
 Is either added to or removed from the old surface.   A disturbance of an
exposed area may also result from the turning of surface material to a
depth exceeding the size of the largest pieces of material present.
     4.1.2.2  Predictive Emission Factor Equation*.   The emission factor
for wind-generated paniculate  emissions from mixtures of credible and
nonerodlble surface material  subject to disturbance  may be expressed 1n
units of g/m*-yr as follows:
                                             N
                       Emission factor » k   J   PI                   (4-3)
                                  4-5

-------
                                                        tarn
                                               Srteo AT 2
                                         WtttO -S/Veo  Ar IOm
Figure 4-1.  Illustration of  logarithmic velocity profile.

-------
     This distribution of particle sUt within tht < 30 * fraction 1s
comparable to the distributions rtporttd for other fugitive dust sources
where wind SP0^ 1« • factor.  This Is Illustrated, for example. 1n tht
distributions for batch and continuous drop operations encompassing 4
number of test aggregate Mterlals (see AP-42 Section 11.2.3).
     In calculating Mission factors, each area of an credible  surface
that Is subject to a different frequency of disturbance should  be treated
separately. For a surface disturbed dally. N • 365/yr, and for  a surface
disturbance once every 6 BO, N • 2/yr.
     The erosion potential function for a dry, exposed suiface  has the
following font:

            P • 58 (u* - u*)t «- 25 (u* - up                 .       (<-3)
            P • 0 for u* s u£
where:  u* • friction velocity («/s)
        u* • threshold friction velocity («/$)
Because of the nonlinear fora of the erosion potential function, each
erosion event oust be treated separately.
     Equations 4-2 and 4-3 apply only to dry. exposed Materials with
Halted erosion potential.  The resulting calculation Is valid only for a
t1«e period as lor A? or longer than the period between disturbances.
     For uncrusted surfaces, the threshold friction velocity 1s best
estimated from the dry aggregate structure of the soil.  The threshold
                      -.                                t
friction velocity for erosion can be determined from the code of the
aggregate size distribution, following a relationship derived by Gillette
(1980) as shown In Figure 4-4.»  A simple hand-sieving test of surface
soil Is highly desirable to determine the mode of the surface aggregate  .
size distribution by Inspection of relative sieve catch aaounts, follow-
ing the procedure specified in Figure 4-5.
     A more approximate basis for determining threshold friction velocity
would be based on hand sieving with just one sieve, but otherwise follows
the procedure specified 1n Figure 4-5.  Based ™ the relationship
                               4-8

-------
I
to
tr 1000 .
Threshold Friction Velocity, u« t (cm/set
o 8
M W * CM •«*•• M U * (M »«*••
















^
















^
















.^

















X


































X

















••
































^^
.^^















^^p'
















X*

















X

















X

















••

















^

















.
















_^
<^
















^


































^

















+
















4
















4

















.












2 348 67*B 2 345 67M 2 S 4 S • 7it
                       0.1
            1                   10

Aggregate Size Distribution Mode (mm)
100
              Figure 4-4.  Relationship of threshold friction velocity to size distribution node.

-------
                           Attachment  2

Excerpts  from  Compilation  of Air   Pollutant  Emission  Factors
(EPA85b, et seq)
                                62

-------
                            AP-42
                       Fourth Edition
                      September 1985
    COMPILATION
            OF
   AIR POLLUTANT
EMISSION FACTORS
         Volume I:
     Stationary Point
    And Area Sources
      U.S. ENVIRONMENTAL PROTECTION AGENCY
         Office Of Air And Radiation
      Office Of Air Quality Planning And Standards
      Research Triangle Park. North Carolina 27711

           September 1985

-------
 11.2.1   UNPAVED ROADS

 11.2.1.1   General

      Dust  plumes trailing  behind vehicles traveling on unpaved roads are a
 familiar sight  in  rural areas of the United States.  When a vehicle travels an
 unpaved  road, the  force of the wheels on the road surface causes pulverization
 of surface material.  Particles are lifted and dropped from the rolling wheels,
 and  the  road surface is exposed to strong air currents in turbulent shear with
 the  surface.  The  turbulent wake behind the vehicle continues to act on the
 road surface after the vehicle has passed.

 11.2.1.2   Emissions Calculation And Correction Parameters

      The quantity  of dust  emissions from a given segment of unpaved road varies
 linearly with the  volume of traffic.  Also, field investigations have shown
 that emissions  depend on correction parameters (average vehicle speed, average
 vehicle weight,  average number of wheels per vehicle, road surface texture and
 road surface moisture) that characterize the condition of a particular road and
 the  associated  vehicle traffic.1'4

      Dust  emissions from unpaved roads have been found to vary in direct.
 proportion to the  fraction of silt (particles smaller than 75 micrometers in
 diameter)  in the road surface materials.1  The silt fraction is determined by
 measuring  the proportion of loose dry surface dust that passes a 200 mesh
 screen, using the  ASTM-C-136 method.  Table 11.2.1-1 summarizes measured silt
 values for industrial and  rural unpaved roads.

      The silt content of a rural dirt road will vary with location, and it
 should be  measured.  As a  conservative approximation, the silt content of the
 parent soil in  the area can be used.  However, tests show that road silt con-
 tent  is normally lower than in the surrounding parent soil, because the fines
 are  continually  removed by the vehicle traffic, leaving a higher percentage
 of coarse  partttles.

      Unpaved roads have a  hard, generally nonporous surface that usually dries
 quickly after a  rainfall.   The temporary reduction in emissions caused by
 precipitation may  be accounted for by not considering emissions on "wet" days
 (more than 0.254 millimeters [0.01 inches] of precipitation).

      The following empirical expression may be used to estimate the quantity of
 size  specific particulate  emissions from an unpaved road, per vehicle kilometer
 traveled (VKT) or  vehicle  mile traveled (VMT), with a rating of A:

                   /s\  /S\  /W\0-7    /w\0.5   /365-p\
      E-kC1.7>   (_)  (—)  (—      (—       	)     Ug/VTCT)
                  W  V»8/  \2.7j     VA/     \365/

                   /s\  /S\   /W*.7    /tf>P.5   /365_pV
     E-k(5.9>   (—)  [ —-)  (—)      —)      	)     (Ib/VMT)
                  W  W  w      w     \3*v

9/88                          Miscellaneous Sources                    11.2.1-1

-------
K»
K>
                         TABLE 11.2.1-1.   TYPICAL SILT CONTENT VALUES OP SURFACE MATERIAL

                                      ON INDUSTRIAL AND RURAL UNPAVED ROADS*


Industry
Copper smelting
Iron and steel production
Sand and gravel processing
Stone quarrying and processing
Taconlte alnlng and processing

Western surface coal mining




Rural roads


i
Road use or
surface material
Plant road
Plant road
Plant road
Plant road
Haul road
Service road
Access road
Haul road
Scraper road
Haul road
. (freshly
graded)
Gravel
Dirt
Crushed limestone

Plant
sites
1
9
1
1
1
1
2
3
3

2
1
2
2

Test
samples
3
20
3
5
12
8
2
21
10

5
1
5
8

Silt (in
Range I
-
15.9 - 19.1
4.0 - 16.0
4.1 - 6.0
10.5 - 15.6
3.7 - 9.7
2.4 - 7.1
4.9 - 5.3
2.8 - 18
7.2 - 25

18 - 29
NA
5.8 - 68
7.7 - 13

t. X)
Mean
17.0
8.0
4.8
14.1
5.8
4.3
5.1
8.4
17

24
5.0
28.5
9.6
PI
M
M
O
£
 00
 oo
References 4-11.  NA - Not available.

-------
 where:   E   emission factor
             particle size Multiplier  (dimensionless)
             silt content  of road  surface material  (Z)
             mean vehicle  speed, km/hr (mph)
             mean vehicle  weight,  Mg (ton)
             mean number of wheels
             number of days with at least 0.254 mm
             (0.01 in.) of precipitation per year

 The  particle size multiplier, k,  in the equation varies with aerodynamic particle
 size range as follows:

                Aerodynamic Particle Size Multiplier For Equation
PO urn*
1.0
_OO urn
0.80
<15 urn
0.50
jCIO urn
0.36
<[5um
0.20
<2.5 urn
0.095
           Stokes  diameter

     The  number of wet days per year, p, for the geographical area of interest
should be  determined from local climatic data.  Figure  11.2.1-1 gives the
geographical distribution of  the mean annual number of  wet days per year in the
United States.

     The  equation retains the assigned quality rating,  if applied within the
ranges of  source  conditions that were tested in developing the equation, as
follows:

                    Ranges Of Source Conditions For Equation
Road silt
content
(wgt. Z)
4.3 - 20
Mean vehicle weight
Mg
2.7 - 142
ton
3 - 157
Mean vehicle speed
km/hr
21 - 64
mph
13 - 40
mean no.
of wheels
4-13
Also, to retain the quality rating of the equation when addressing a specific
unpaved road, it  is necessary that reliable correction parameter values be
determined for the road in question.  The field and laboratory procedures for
determining road  surface silt content are given in Reference 4.  In the event
that site specific values for correction parameters'cannot be.obtained, the
appropriate mean,  values from Table 11.2.1-1 may be used, but the quality rating
of the equation is reduced to B.

     The equation was developed for calculating annual average emissions, and
thus, is to be multiplied by annual vehicle distance traveled (VDT).  Annual
average values for each of the correction parameters are to be substituted for
the equation.  Vorst case emissions, corresponding to dry road conditions, may
be calculated by  setting p - 0 in the equation (equivalent to dropping the last
9/88
Miscellaneous Sources
11.2.1-3

-------
                                          Reproduced from

                                          bail •valUbl* copy.
                 . . I
 t/1
 o
 z
K
                                                                                    MUIS
CD

00
           Figure  11.2.1-1.  Hean number of days with  0.01 Inch or  more of precipitation  in  United States.
)0

-------
 tera from Che  equation).   A separate set of nonclimatic correction parameters
 and  a higher than  normal VDT value may also be justified for the worst case
 average  period (usually 24 hours).  Similarly, in using the equation to calcu-
 late emissions for a  91 day season of the year, replace the term (365-p)/365
 with the term  (91-p)/91, and set p equal to the number of wet days in the 91 day
 period.   Also,  use appropriate seasonal values for the nonclimatic correction
 parameters  and for VDT.

 11.2.1.3 Controls

      Common control techniques for unpaved roads are paving, surface treating
 with penetration chemicals,  working into the roadbed of stabilization chemicals,
 watering, and  traffic control regulations.  Chemical stabilizers work either by
 binding  the surface material or by enhancing moisture retention.  Paving, as a
 control  technique,  is often not economically practical.  Surface chemical treat-
 ment  and watering  can be accomplished with moderate to low costs, but frequent
 retreatments are required.   Traffic controls, such as speed limits and traffic
 volume restrictions, provide moderate emission reductions but may be difficult
 to enforce.  The control efficiency obtained by speed reduction can be calcu-
 lated using the predictive  emission factor equation given above.

      The control efficiencies achievable by paving can be estimated by comparing
 emission factors for unpaved and paved road conditions, relative to airborne
 particle size  range of.interest.  The predictive emission factor equation for
 paved roads, given  in Section 11.2.6, requires estimation of the silt loading
 on the traveled portion of  the paved surface, which in turn depends on whether
 the  pavement is periodically cleaned.  Unless curbing is to be installed, the
 effects  of  vehicle  excursion onto shoulders (berms) also must be taken into
account  in  estimating control efficiency.

     The control efficiencies afforded by the periodic use of road stabilization
 chemicals are  ouch  more difficult to estimate.  The application parameters
which determine control efficiency include dilution ratio,- application intensity
 (mass of diluted chemical per road area) and application frequency.  Other
factors  that affect the performance of.chemical stabilizers include vehicle
characteristics (e. g., traffic volume,  average weight) and road characteristics
 (e. g.,  bearing strength).

     Besides water, petroleum resin products have historically been the dust
suppressants most widely used on industrial unpaved roads.  Figure 11.2.1-2
presents a  method  to estimate average control efficiencies associated with
petroleum resins applied to unpaved roads.  Several items should be noted:

      1.  The term "ground  inventory" represents the total volume (per
         unit area) of petroleum resin concentrate (not solution)
         applied since the  start of the dust control season.

     2.  Because petroleum  resin products must be periodically reapplied
         to unpaved roads,  the use of a time-averaged control efficiency
         value is appropriate.  Figure 11.2.1-2 presents control effi-
         ciency values averaged over two common application intervals,
         two weeks and one month.  Other application intervals will
         require interpolation.


 9/88                        Miscellaneous Sources                     11.2.1-5

-------
S
M
vt
to
O
Z
        100
                    0.25
                         0.5
                                  GROUND INVENTORY

                                  (liters/square meter)

                              0.75       1    0       0.25
                                                     0.5
                  0.75
o
z
UJ

o
u.
u.
LJ
_J
O
cc
H

o
o
LLJ
O
<
GC
UJ
                     T
                          T
                               T
                              T
              Note: Averaging periods (2 weeks or 1 month)
                   refer  to time between applications
         80 -
         60
40
         20
           0
                             2 weeks
                             1 month
                               TOTAL PARTICULAR
                                               I
T
                                                                              1 month
                                                               PARTICLES  =  10  |imA
0.05      0.1      0.15      0.2  0.25   0     0.05

                          (gallons/square yard)


                          GROUND INVENTORY
                                                               0.1
                                                                            O.t5
                                                                                         0.2
                                 0.25
 oo
 oo
              Figure 11.2.1-2.  Average control efficiencies  over common application Intervals.

-------
11.2.2  AGRICULTURAL TILLING

11.2.2.1  General

     the two  universal  objectives of agricultural tilling are the creation
of the desired soil structure to be used as the crop seedbed and the eradi-
cation of weeds.   Plowing,  the most common method of tillage,  consists  of
some form of cutting loose, granulating and inverting the soil,  and turning
under the organic  litter.   Implements that loosen the soil and cut off the
weeds but leave  the  surface trash in place have recently become more popu-
lar for tilling in dryland farming areas.

     During a tilling operation, dust particles from the loosening and pul-
verization of  the  soil  are injected into the  atmosphere  as  the soil is
dropped to the surface.  Dust emissions  are greatest during periods of dry
soil and during final seedbed preparation.

11.2.2.2  Emissions and Correction Parameters

     The quantity  of dust  from  agricultural tilling is proportional to the
area of land  tilled.  Also, emissions depend  on surface soil texture and
surface soil  moisture  content,  conditions  of a particular  field being
tilled.

     Dust emissions  from  agricultural  tilling have been found to vary di-
rectly with the  silt content (defined as particles  < 75 micrometers in di-
ameter) of the surface soil depth (0 to  10 cm  [0 to 4 in.]).  The soil silt
content is determined by measuring the proportion of dry soil that passes a
200 mesh screen,  using  ASTM-C-136 method.  Note that  this  definition of
silt differs  from  that  customarily used by soil scientists, for whom silt
is particles from 2 to 50 micrometers in diameter.

     Field measurements2  indicate that  dust  emissions  from agricultural
tilling are not  significantly related to surface soil moisture,  although
limited earlier  data had  suggested such  a dependence.1   This  is now be-
lieved to reflect  the  fact that most tilling  is performed under  dry soil
conditions, as were the majority of the  field  tests.1"2

     Available test data indicate no substantial dependence of emissions on
the type of tillage  implement, if operating at a typical speed (for exam-
ple, 8 to 10 km/far [5 to 6 mph]).1'2

11.2.2.3  Predictive Emission Factor Equation

     The quantity  of dust  emissions  from agricultural  tilling,  per acre  of
land tilled, may be estimated with a rating of A or B (see below) using  the
following empirical expression2:

                        E =  k(5.38)(s)°'6   (kg/hectare)               (1)

                        E =  ktt.SOXs)0'6   (Ib/acre)

5/83                       Miscellaneous  Sources                    11.2.2-1

-------
     where:  E = emission  factor
             k = particle  size multipler  (
             s - silt  content of  surface  soil  (I)

The  particle  size  multiplier (k)  in  the  equation varies  with  aerodynamic
particle size range as follows:

             Aerodynamic Particle Size Multiplier for Equation 1
Total
particulate
1.0
< 30 M°>
0.33
< 15 MB
0.25
< 10 [in
0.21
< 5 M»
0.15
< 2.5 [ao
0.10
     Equation  1 is rated A  if used to estimate total particulate emissions,
and B if used  for a specific particle size range.  The equation retains its
assigned quality  rating if applied within the  range of  surface soil silt
content  (1.7  to 88 percent) that was tested  in developing the equation.
Also, to retain the  quality rating of Equation  1  applied to a  specific ag-
ricultural  field,  it is necessary to obtain  a  reliable  silt value(s) for
that field.   The  sampling  and  analysis  procedures for  determining agricul-
tural silt content are  given in Reference 2.  In the event that a site spe-
cific value  for silt content cannot be  obtained,  the mean value of  18 per-
cent may be  used,  but the  quality rating  of the equation is reduced by one
level.

11.2.2.4  Control Methods3

     In general,  control methods are not applied to reduce emissions from
agricultural  tilling.   Irrigation of  fields  before plowing will reduce
emissions, but in many cases,  this practice would make the soil unworkable
and would  adversely affect the plowed soil's characteristics.  Control
methods  for  agricultural  activities  are aimed primarily at  reduction of
emissions from wind  erosion through such  practices as  continuous cropping,
stubble mulching,  strip cropping, applying limited irrigation to  fallow
fields, building  windbreaks, and using chemical stabilizers.   No data are
available to  indicate the   effects of these or  other control methods on
agricultural tilling,  but  as a practical matter,  it may be  assumed that
emission reductions are not significant.

References for Section  11.2.2

1.   C. Cowherd, Jr., et al., Development of Emission Factors for Fugitive
     Dust Sources, EPA-450/3-74-037,  U. S. Environmental Protection Agency,
     Research Triangle Park, NC, June 1974.

2.   T. A.  Cuscino,  Jr.,  et al., The Role of Agricultural Practices in
     Fugitive Dust Emissions, California  Air  Resources Board,  Sacramento,
     CA, June  1981.

3.   G. A Jutze, et al., Investigation of Fugitive Dust  - Sources Emissions
     And Control,  EPA-450/3-74-036a,  U. S. Environmental Protection Agency,
     Research Triangle Park, NC, June 1974.                                             „uJ

11.2.2-2                      EMISSION FACTORS                          5/83

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 11.2.3  AGGREGATE HANDLING AND STORAGE  FILES

 11.2.3.1  General

      Inherent in operations that  use mineral!  in aggregate form is the
 maintenance of outdoor storage piles.   Storage piles are usually left uncovered,
 partially because of the need for frequent material transfer into or out of
 storage.

      Dust emissions occur at several points in the storage cycle, such as
 during material loading onto the  pile,  disturbances by strong wind currents,
 and loadout from the pile.  The movement of trucks and loading equipment in the
 storage pile area is also a substantial source of dust.

 11.2.3.2  Emissions And Correction Parameters

      The quantity of dust emissions from aggregate storage operations varies
 with the volume of aggregate passing through the storage cycle.  Also, emis-
 sions depend on three  parameters  of the condition of a particular storage pile:
 age of the pile,  moisture content and proportion of aggregate fines.

      When freshly processed aggregate is loaded onto a storage pile, its
 potential for dust emissions is at a maximum.  Fines are easily disaggregated
 and released to the atmosphere upon exposure to air currents, either from aggre-
 gate transfer itself or from high winds.  As the aggregate weathers, however,
 potential for dust emissions  is greatly reduced.  Moisture causes aggregation
 and cementation of fines to the surfaces of larger particles.  Any significant
 rainfall soaks  the interior of the pile, and the drying process is very slow.

      Silt (particles equal to or  less than 75 microns in diameter) content is
 determined  by measuring the portion of dry aggregate material that passes
 through  a 200 mesh screen,  using  ASTM-C-136 method.  Table 11.2.3-1 summarizes  •
 measured silt and moisture  values  for industrial aggregate materials.

 11.2.3.3  Predictive Emission Factor Equations

      Total  dust  emissions from aggregate storage piles are contributions of
 several  distinct  source activities within the storage cycle:
      1.   Loading  of aggregate onto storage piles (batch or continuous drop
          operations).
     .2.   Equipment traffic  in storage area.         /
      3.  Wind erosion of  pile  surfaces and ground areas around piles.
     A.   Loadout  of  aggregate  for  shipment or for return to the process stream
          (batch or  continuous drop operations).

     Adding  aggregate material  to a storage pile or removing it both usually
involve dropping  the material onto a receiving surface.  Truck dumping on the
pile or  loading out  from  the  pile  to a truck with a front end loader are exam-
ples of batch drop  operations.  Adding material to the pile by a conveyor
stacker  is an example of  a  continuous drop operation.


 9/88                        Miscellaneous Sources                     11.2.3-1

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                               TABLE 11.2.3-1.   TYPICAL SILT AND MOISTURE CONTENT VALUES

                                          OF MATERIALS AT VARIOUS INDUSTRIES
Industry
Iron and steel
production*








Stone quarrying
and processing0
Taconlte mining
and processing0

Western surface
coal ralnlngd
.

Coal fired power
generation6
Material

Pellet ore
Lump ore
Coal
Slag
Flue dust
Coke breeze
Blended ore
Sinter
Limestone
Crushed
limestone

Pellets
Tailings

Coal
Overburden
Exposed ground

Coal
Silt (Z)
No. of test
samplers Range Mean

10
9
7
3
2
I
1
1
1

2

9
2

15
IS
3

60

1.4 - 13
2.8 - 19
2 - 7.7
3 - 7.3
14 - 23





1.3 - 1.9

2.2 - 5.4
NA

3.4 - 16
3.8 - 15
5.1 - 21 ,

0.6 - 4.8

4.9
9.5
5
5.3
18.0
5.4
15.0
0.7
0.4

1.6

3.4
11.0

6.2
7.1
15.0

2.2
Moisture '(Z)
No. of test
samplers Range Mean

8
6
6
3
0
1
1
0
0

2

7
1
•
7
0
3

59

0.64 - 3.5
1.6 - 8.1
2.8 - 11
0.25 - 2.2
NA


NA
NA

0.3 - 1.1

0.05 - 2.3


2.8 - 20
NA
0.8 - 6.4

2.7 - 7.4

2.1
5.4
4.8
0.92
NA
6.4
6.6
NA
NA

0.7

0.9
0.35

6.9
NA
3.4

4.5
ro
.
u»
I
N>
 tn
 en
 I
     'References  2-5.  NA - not applicable.

     Reference  1.
     r*

     'Reference  6.

     Reference  7.
 09
     nei ei diets  i ,

       eference  8.   Values  reflect  "as  received"  conditions of a  single power plant.

-------
      The  quantity of  particulate emissions generated by either type of drop
 operation,  per  ton of material transferred, may be estimated, with a rating of
 A,  using  the  following empirical expression^:
              k(0.0016)
       (kg/Mg)
          E - k(0.0032)
       (Ib/ton)
where:  E - emission factor
        k - particle size multiplier (dimensionless)
        U .• mean wind speed, m/s (mph)
        M - material moisture content (Z)

The particle size multiplier, k, varies with aerodynamic particle diameter, as
shown in Table 11.2.3-2.
           TABLE  11.2.3-2.  AERODYNAMIC PARTICLE SIZE MULTIPLIER (k)
<30 urn
0.74
<15 urn
0.48
<10 urn
0.35
<5 urn
0.20
<2.5 urn
0.11
     The equation retains the assigned quality rating if applied within the
ranges of source conditions that were tested in developing the equation, as
given in Table 11.2.3-3.  Note that silt content is included in Table 11.2.3-3,
even though silt content does not. appear as a correction parameter in the equa-
tion.  While it is reasonable to expect that silt content and emission factors
are interrelated, no significant correlation between the two was found during
the derivation of the equation, probably because most tests with high silt
contents were conducted under lower winds, and vice versa.  It is recommended
that estimates from the equation be reduced one quality rating level, if the
silt content used in a particular application falls outside the range given in.
Table 11.2.3-3.
9/88
Miscellaneous Sources
11.2.3-3

-------
           TABLE 11.2.3-3.  RANGES OF SOURCE CONDITIONS FOR EQUATION 1
Silt
Content
0.44 - 19
•*
Moisture
Content
0.25 - 4.8
Wind Speed
(n/s) (mph)
0.6 - 6.7 1.3 - 15
      Alto, to retain the equation's quality rating when applied to a specific
 facility, it is necessary that reliable correction parameters  be  determined for
 Che specific sources of interest.   The  field and  laboratory  procedures for
 aggregate sampling are given in Reference 3.  In  the  event that site specific
 values for correction paraaeters cannot be obtained,  the appropriate mean
 values from Table 11.2.3-1 may be  used, but, in that  case, the quality rating
 of the equation is reduced by one  level.

      For emissions from equipment  traffic (trucks,  front end loaders, dozers,
 etc.) traveling between or on piles,  it is recommended that  the equations for
 vehicle traffic on unpaved surfaces be  used (see  Section 11.2.1).  For vehicle
 travel between storage piles, the  silt  value(s) for the areas  among the piles
 (which may differ from the silt values  for the stored materials)  should be used.

      Worst case emissions from storage  pile areas occur under  dry windy condi-
 tions.  Worst case emissions from  materials handling  operations may be calcu-
 lated by substituting into the equation appropriate values for aggregate material
 moisture content and for anticipated wind speeds  during the  worst case averaging
 period,  usually 24 hours.  The treatment  of dry conditions for vehicle traffic
 (Section 11.2.1), centering on parameter p, follows the methodology described
 in Section 11.2.1.   Also, a separate  set  of nonclimatic correction parameters and
'source extent values corresponding to higher than normal storage  pile activity
 may be Justified for the worst case averaging period.

'11.2.3.4  Controls

      Watering and chemical wetting agents are the principal  means for control
 of aggregate  storage pile emissions.  Enclosure or  covering  of inactive piles
 to reduce wind erosion can also reduce  emissions.   Watering  is useful mainly to
 reduce emissions from vehicle traffic in  the storage  pile area.  Watering of
 the storage piles themselves typically  has only a very temporary  slight effect
 on total  emissions.   A much more effective technique  is to apply  chemical wet-
 ting agents for better vetting of  fines and longer  retention of the moisture
 film.   Continuous chemical treatment  of material  loaded onto piles, coupled
 with watering or treatment of roadways, can reduce  total participate emissions
 from aggregate storage operations  by  up to 90 percent.9


 References  for Section 11.2.3

 1.   C.  Cowherd, Jr., et al., Development  Of Emission  Factors For  Fugitive Dust
     Sources.  EPA-450/3-74-037, U.  S.  Environmental  Protection  Agency, Research
     Triangle  Park,  NC, June 1974.
11.2.3-4                        EMISSION FACTORS
                                                                           9/88

-------
                                   APPENDIX C.3

                             SILT ANALYSIS PROCEDURES
  1.  Select the appropriate 8 inch diameter 2 inch deep sieve  sizes.
      Recommended standard series sizes are 3/8 inch No. 4,  No.  20, No.  40,
      No. 100, No. 140, No. 200, and a pan. Jhe No.  20 and  the  No. 200  are
      mandatory.  Comparable Tyler Series sizes can also be  used.  ' •

  2.  Obtain a mechanical sieving device such  as a  vibratory shaker or a
      Roto-Tap (without the tapping function).

  3.  Clean'the sieves with compressed air and/or a soft brush.  Material lodged
      in the sieve openings or adhering to the sides  of  the  sieve should be
      removed without handling the screen roughly,  if possible.
»
  4.  Obtain a scale with capacity of at least 1600 grams, and record its make,
      capacity, smallest increment, date of last calibration, and accuracy.

  5.  Record the tare weight of sieves and pan, and check the zero before every
     .weighing.

  6.  After nesting the sieves in decreasing order  of hole size, and with the
      pan at the bottom, dump dried laboratory sample into the top sieve,
      preferably immediately after moisture analysis.  The sample should weigh
      between 800 end 1600 grams (1.8 and 3.5  pounds).   Brush fine material
      adhering to the sides of the container into the top sieve, and cover  the
      top sieve with a special lid normally purchased with the pan.

  7.  Place nested sieves into the mechanical  device, and sieve  for  10 minutes.
      Remove pan"containing minus No. 200 and  weigh its  contents.  Repeat the
      sieving in 10 minute intervals until the difference between two successive
      pan sample weights is less than 3.0 percent when the tare  of the pan has
      been substracted.  Do not sieve longer than 40 minutes.

  8.  Weigh each sieve and its contents, and record the  weight.  Remember to
      check the zero before every weighing.

  9.  Collect the laboratory sample, and place it in a separate  container if
      further analysis is expected.

10.  Calculate the percent of mass less than  the 200 mesh screen (75 micro-
     meters).   This  is the silt content.
9/88                               Appendix  C.3                             C.3-1

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                           Attachment 3

                          Excerpts from

Hazardous Waste TSDF  (Treatment, Storage, and Disposal Facilities) :
Fugitive  Particulate  Matter  Air  Emissions  Guidance  Document
(EPA89a)
                                63

-------
                                                            PB90-103250
 Hazardous Waste TSDF (Treatment, Storage,  and Disposal Facilities)
 Fugitive Participate Matter Air Emissions  Guidance Document
 Midwest Research Inst.,  Kansas City,  MO




•Prepared for:

 Environmental  Protection Agency,  Research Triangle  Park,,  NC




 May 89

-------
.Items 1 and 4  (pile formation and removal) fall under the general cate-.
gory of. materials handling as discussed below.  Equipment traffic In tw
waste pile area occurs primarily In association >1tn pile formation and'
removal.

3.2.1  Materials Handling
     Adding waste material to a storage pile o~ removing 1t usually
Involves dropping the material onto a receiving surface.  Truck dumping
on  the pile or loading out from the pile to a truck with a front-end
loader are examples of batch drop operations.  Adding material to the
pile by a conveyor stacker 1s an example of a continuous drop operation.
     The following equation 1s recommended for estimating emissions from
transfer operations (batch or continuous drop):

                                   Uvl-3
                         k(0.0016) y-*/L4   (kg/Mg)
                                  6)  *
                                                                    (3-1)
                                      1.3
                     e  •  k(0.0016))5/       (Ib/ton)
where:  e • emission factor
        k • particle size multiplier (d1mens1onless)
      .  U • mean wind speed, m/s (mph)
        M • material moisture content, X                        •

The particle size multiplier k varies with aerodynamic particle diameter
as shown below:

                 Aerodynamic Particle Size Multiplier, k
     <30 UM        <1S ua        <10 um        *S urn          <2.5
                        u             u          *   u              .  um
                    TT3T       ~OT        "OB            0.11
                                3-5

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                 Attachment 4



Excerpts from National Agronomy Manual (DOA88)
                      64

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                        Subpart D -  WEQ Factors
                        SUBPART D - WEQ FACTORS

                                                              502.31(a)

5502.30  The Wind Erosion Estimate - £.

   The wind erosion estimate £ is the estimate of average annual tons
of soil per acre that the vind vill erode from an area represented by
an unsheltered distance L and for the soil, climate, and site
conditions represented by J, £, £, and 2.  The equation is an
empirical formula developed by relating vind tunnel data to observed
field erosion during a 3-year period in the mid-1950's [86].  The
field data was normalized to reflect long-term average annual erosion
assuming given conditions during the critical period without reference
to change in those-conditions through the year.  The estimate arrived
at by using the critical wind erosion period method does not track
specific changes brought about by management and crop development; nor
does it assume that critical period conditions exist all year.  The
calibration procedure accounted for minor changes expected to occur
during a normal crop year at that time in history.  However, these
changes were not quantified nor described in the documentation and
field publications.  The WEQ annual £ is based on an annual £ and
field conditions during the critical wind erosion period of the year.
This procedure does not account for all the effects of management.

The management period method of estimating wind erosion involves
assigning factor values to represent field conditions expected to
occur during specified time periods.  Using annual wind energy
distribution data, erosion can be estimated for each period of time
being evaluated.  The time period estimates can be summed to arrive at
an annual estimate.  Cropping sequences involving more than one year
can be evaluated using this procedure.  It also allows for a more
thorough analysis of a management system and how management techniques
affect the erosion estimate.
§502.31  Soil credibility index - I.

   (a)  I is the erodibility factor for the soil on the site.   It is
expressed as the average annual soil loss per acre that would  occur
from wind erosion, assuming the site were—

         Isolated (incoming saltation is absent).
      .  Level (knolls are absent).
         Smooth (ridge roughness effects are absent).
      .  Unsheltered (barriers are absent).
      .  At a location where the £ factor is 100.
      .  Bare (vegetative cover is absent).
      .  "Wide" (the distance at which the flow of eroding soil
         reaches its maximum and does not increase with field  size).

                                                                 502-15
                  (190-V-HAM, Second Ed., March 1988)

-------
                        Part 502 - Wind Erosion

502.31(a)

      .  Loose and noncrusted (aggregates not bound together, and
         surface not sealed.  However, clods may be present).

   (b)  This factor is related to the percentage of nonerodible
surface soil aggregates larger than 0.84 am in diameter.  For most SCS
uses, the I value is assigned for named soils based on wind
credibility groups (WEG).  The WEG is included on SCS soil
interpretation records.  If the soil name is not known, Exhibit
502.61(a) can be used to determine the WEG from the surface soil
texture.

   (c)  To determine erodibility for field conditions during a
management period,  follow sieving instruction in Exhibit 502.61 (b).
(Do not use this procedure to determine average annual I values).

   (d)  A soil erodibility index based solely on the percentage of
aggregates larger than 0.84 mm has several potential sources of
error.  Some of these are:

      (1)  The relative erodibility of widely different soils may
change with a change in wind velocity over the surface of the soil.

      (2)  Calibration of the equation is based on the volume of soil
removed, but the erodibility index is based on weight.

      (3)  Differences in size of aggregates have considerable
influence on erodibility but no distinction for this influence is made
in Table 1, Exhibit 502.61(b).

      (4)  Stability of surface aggregates influences erodibility;
large durable aggregates can become a "surface armor"; less stable
aggregates can be abraded into smaller, more erodible particles".

      (5)  Surface crusting can greatly reduce erodibility;
erodibility may increase again as the crust deteriorates [20].

   (e)  Knoll erodibility.—Knolls are topographic features
characterized by short, abrupt windward slopes.  Wind erosion
potential is greater on knoll slopes than on level or gently rolling
terrain because wind flowlines are compressed and wind velocity
increases near the crest of the knolls.  Erosion that begins on knolls
often affects field areas downwind (figure 502-3).

Adjustments of the Soil Erodibility Index (I) are used where
windward-facing slopes are less than 500 feet long and the increase in
slope gradient from the adjacent landscape is 3 percent or greater.
Both slope length and slope gradient change are determined along the
direction of the prevailing erosive wind (figure 502-4).
502-16
                  (190-V-HAM, Second Ed., March 1988)

-------
                        Part 502 - Wind Erosion

502.31(e)

        Table 502-1.  Knoll credibility adjustment  factor  for I.


Slope Change
in Prevailing Wind
Erosion Direction
3
4
5
6
8
10
10 - 15*
15 - 20
20+
A

Knoll
Adjustment
to 1
1.3
1.6
1.9
2.3
3.0
3.6
2.0
1.4
1.0
B
Increase
at Crest Area
Where Erosion
Is Most Severe
1.5
1.9
2.5
3.2
4.8
6.8



*Factors above 10 percent slope change based  on SCS  judgment.  Ho
research data available.

No adjustment of I for knoll erodibility is made on  level  fields, or
on rolling terrain where slopes are longer and slope changes are less
abrupt.  Where these situations occur, the wind flow pattern tends to
conform to the surface and does not exhibit the flow constriction
typical of knolls (figure 502-5).

            Wind direction                            *"

     Figure 502-5  Windflow over Level or Rolling Surfaces
  
-------
                           Subp*r« D - WEQ Factors
                                                                   502.31(e)
                                                     ?,
                  Figure 502-3 Downwind Effect of Knolls
       Prevailing wind
       t ration direction
                         Knoll credibility odjuttment
                         applies here
Deposition occurs her*
                                                    Compressed air flow
                                                   Greatest credibility
                                 Slope change 23%    o""'8 here
                         Windword slope < 500 feet
                       Figure 602-4  Knoll Erodlbllity
Table  502-1 contains knoll erodibility adjustment factors  for the Soil
Zrodibility Index I.  The I value for the Wind Erodibility Group is
multiplied by the factor' shown in Column A.   This adjustment  expresses
the average increase in credibility along the knoll slope.  For
comparison, Column B shows the increased erodibility near  the crest
(about  the upper 1/3 of the slope), vhere the effect is most  severe.
                   (190-V-RAM,  Second Ed., March 1988)
                                                                    502-17

-------
                        Subpart D - WEQ Factors
                        SUBPAET D - WEQ FACTORS

                                                              502.31(a)

SS02.30  The Wind Erosion Estimate - £.

   The wind erosion estimate £ is the estimate of average annual tons
of soil per acre that the vind vill erode from an area represented by
an unsheltered distance It and for the soil, climate, and site
conditions represented by I, g, £, and 2.  The equation is an
empirical formula developed by relating vind tunnel data to observed
field erosion during a 3-year period in the mid-1950's [86].  The
field data vas normalized to reflect long-term average annual erosion
assuming given conditions during the critical period without reference
to change in those-conditions through the year.  The estimate arrived
at by using the critical vind erosion period method does not track
specific changes brought about by management and crop development; nor
does it assume that critical period conditions exist all year.  The
calibration procedure accounted for minor changes expected to occur
during a normal crop year at that time in history.  However, these
changes were not quantified nor described in the documentation and
field publications.  The WEQ annual £ is based on an annual £ and
field conditions during the critical vind erosion period of the year.
This procedure does not account for all the effects of management.

The management period method of estimating vind erosion involves
assigning factor values to represent field conditions expected to
occur during specified time periods.  Using annual vind energy
distribution data, erosion can be estimated for each period of time
being evaluated.  The time period estimates can be summed to arrive at
an annual estimate.  Cropping sequences involving more than one year
can be evaluated using this procedure.  It also allows for a more
thorough analysis of a management system and hov management techniques
affect the erosion estimate.
{502.31  Soil credibility index - I.

   (a)  I is the credibility factor for the soil on the site.  It is
expressed as the average annual soil loss per acre that vould occur
from vind erosion, assuming the site vere—

      .  Isolated (incoming saltation is absent).
      .  Level (knolls are absent).
      .  Smooth (ridge roughness effects are absent).
      .  Unsheltered (barriers are absent).
      .  At a location vhere the £ factor is 100.
      .  Bare (vegetative cover is absent).
      .  "Vide- (the distance at which the flov of eroding soil
         reaches its maximum and does not increase vith field size).

                                                                 502-15
                  (190-V-KAM, Second Ed., March 1988)

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                 Attachment 4
Excerpts from National Agronomy Manual (DOA88)
                      64

-------
                           Subpart D - VZQ Factors
                                                                   502.31(e)
                  Flour* 602-3 Downwind Effect of Knolls
       Prevailing wind
       trosion direction
                         Knoll erodibility odjuttment
                         opplles here
Deposition occur* here
                                                    Compressed oir flow
                                                   Greatest trodibility
                                                   occurs here
                         Windward slope < 500 feet
                       Flgurt)  502-4  Knoll Erodlbllity
Table 502-1 contain*  knoll erodibility adjustment factors  for the Soil
Krodibility Index I.   The I ralue for  the Wind Erodibility Group is
tniltiplied by the factor* shown in Column A.   This adjuatnent ezpreases
the averafe increase  in erodibility along the knoll slope.   For
comparison, Column B  shows the increased erodibility near  the crest
(about  the upper 1/3  of the slope), where the effect is most severe.
                   (190-V-RAM,  Second Ed., March 1988)
                                                                    502-17

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          Attachment 5



Excerpts from NUREG-0570 (NRC79)
               65

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                                   NUREG-0570
TOXIC VAPOR CONCENTRATIONS IN THE
     CONTROL ROOM FOLLOWING A
   POSTULATED ACCIDENTAL RELEASE
                  Prepared by
                  James Wing
          Manuscript Completed: May 19V»
               Date Published: June 1979
     Division of Site Safety and Environmental Analysis
          Office of Nuclear Reactor Regulation
         U. S. Nuclear Regulatory Commission
             Washington, D.C. 20555

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D.R = 0.0018583        (T  + 273)3/2 (n + i)1/2
 MD                     J	MA  MB                        (2.1.-14)
                         P(JAB2  QAB
     where M. = molecular weight of gas A (g/mole)
          Mg = molecular weight of gas B (g/mole)
          P = atmospheric pressure (atm)
          a =  Lennard - Jones parameter
          fi.g = dimensionless function of temperature and intermolecular
                potential field E.g
     The Lennard-Jones parameter is empirically estimated to  be  an  arithmetic
     mean of the two gases:
     OAB = (OA•+ OB) /2                                             (2.1-15)
     The intermolecular potential  field is empirically estimated to be a
     geometric mean of the two gases:
     EAB = (EA Eg)1*             .                 .                    (2.1-16)
          The values of a, E, and fi for a few compounds are available in  the
     literature (Bird et al,  p.  744; Reid and Sherwood, p.  524,  p.  632).
          Eventually, the air space in the confined building  will be saturated
     with the toxic vapor of the spill, and the vapor concentration will  .
     approach the following value (assuming ideal-gas behavior of the vapor):
     Cs     = a Ps  M	
              Rg (Ta * 273)                                      (2.1-17)

     where Cs = saturation concentration (g/cm )
      R  = universal gas constant
       9
                                     -11-

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     M = molecular weight of the liquid (g/mole)
     Tg = ambient temperature (°C)
     PS = saturation vapor pressure of the liquid (mm Hg)
           •*
This would be the maximum vapor concentration of a liquid that is spilled in
a confined space, such as a basement.

2.1.3.2 .Mass Transfer by Forced Convection
          The evaporation of a liquid in an open space with wind or in  a
     confined area with good ventilation can be described as a mass transfer
     process by forced convection.
          The evaporation rate may be calculated by the "following formulas
     (Eckert and Drake, pp.  470-476):
     (dmy/dt) = hd M A(t) (Ps - Pa)/Rg (Tfl + 273)                     (2.1-18)
     where,  for a laminar flow (Eckert and Drake, pp.  176,  177,  475):
     hd = 0.664 £ (Re)1/2 (Sc)1/3                                     (2.1-19)

     and for a turbulent flow (Eckert and Drake p.  215):
     hd = 0.037 £ (Re)0'8 (Sc)1/3                                     (2.1-20)

          Re = Reynold number = L u p/u
          Sc = Schmidt number = u/Dp
          hrf = mass transfer coefficient (cm/sec)
          R  = universal gas constant
                                        2
          D  = diffusion coefficient (cm /sec.)
          u  = wind speed (cm/sec)
                                   o
          p  = density of air (g/cm )
                                     -12-

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           L  = characteristic length (cm)
           u  = viscosity  of  air  (g/cm sec)
           M  = molecular  weight  of the liquid (g/mole)
           PS = saturation vapor  pressure  of the liquid at temperature
                Ta  (mm  Hg)
           Pa = actual  vapor  pressure of the liquid in air (mm Hg)
           For  water, P may  be computed from the relative humidity (List,
                       a
     p. 347).   For other  liquids, P_ would normally be zero.
                                   a
           The  diameter of the spill area  may be taken as the characteristic
     length, L.  The spill area  and thus  the characteristic length vary with
     time  (eq.  (2.1-1)).

"2.1.4  Comparison  of Calculations With Empirical Data
           A few calculations of  evaporation rates are compared with the available
     empirical  data.   However, the empirical observations were made on evapora-
     tion  of watery from confined sources, such as pools and ponds, where the
     surface areas are already fixed.  Therefore, it is not possible to check
     the dynamic process  of  simultaneous  spreading and evaporation of the
     liquid.

2.1.4.1  Annual Evaporation  of Water
           The  annual evaporation of water from a standard evaporation pan of
     the Weather Bureau has  been measured at many stations throughout the
     United States.  The  data for the period of 1946-1955 have been collected
     (Kohler et al.).
                                         -13-

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          The annual mean temperatures, wind speeds, and relative humidities
     of several geographic regions of the United States have been compiled
     (Lerner, pp. 182-193).  Using this information, it is possible to calculate
     the annual evaporation of water by eqs.  (2.1-18) and (2.1-19).   A
     comparison of the calculated annual evaporation using eq.  (2.1-19) (laminar
     flow) with the experimental data for ten widely separated locations is
     presented in Table 1.  In the calculations, the arithmetic mean of the
     relative humidities was used for each location, and the characteristic
     length was 1.2m (diameter of the standard evaporation pan of the National
     Weather Service).  The agreement is good, with the maximum variation
     being within a factor of 2.

2.1.4.2  Empirical Formulas for Evaporation of Water
          Several formulas for the prediction of evaporation of water from
     pools have been developed empirically (Chow, 11-4; Merritt; Patterson, et
     al.;  Davis and Sorensen).   These are summarized in Table 2 together with
     the calculated*evaporation rates for water at 38°C with a relative humidity
     of 10% and wind speed of 1 m/sec.   The experimental datum obtained under
     this  condition for evaporation on drying trays (Bolz and Tuve) is also
     shown.   Using L = 1.2 m, the evaporation rates computed from eqs. (2.1-18)
     and (2.1-19) (laminar flow) are also presented in Table 2.
          The empirical formulas predict evaporation rates ranging from 0.070
                o                                 2
     to 0.44 g/m  sec, with an average of 0.26 g/m  sec.  The agreement between
     the empirical formulas and the experimental value, and hence eqs. (2.1-18)
     and (2.1-19), is within a factor of 2 in most cases.  The empirical
                                     -14-

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               Table 1  Comparison of Calculated Evaporation Rates

                        cf Water With Experimental Data*
Location Annual
Average
Temperature
(°C)
Phoenix, AR
Los Angeles, CA
Denver, CO
Louisville, KY
New Orleans, LA
Portland, ME
Albuquerque, NM
Blsmark, ND
El Passo, TX
Seattle, WA
21.3
16.5
11.1
13.1
20.2
7.2
13.8
5.2
17.4
10.6
Annual Average Annual
Average Relative Evaporation
Wind Speed Humidity (cm)
(cm/sec) (X) Experimental Eq. (2.1-19)
High-Low
268
277
402
371
375
393
398
478
434
420
53-32
75-53
69-41
81-59
88-63
80-60
57-37
78-56
52-35
83-74
183
117
81
91
124
61
137
86
183
61
179
85
91
66
84
46
126
49
177
43
*Data for annual average temperatures, wind speeds, and relative  humidity  obtained
 from Lerner, pp. 182-193.  Data for annual evaporation from Kohler et  al.
                                          - 15 -

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                    Table 2  Comparison of Calculated Evaporation Rates
                             of Water by Several Formulas
Ambient Temperature = 38°C
Relative Humidity = 10%
Wind Speed = 1 m/sec
Formula
FitzGerald
Meyer, small pool:
      large reservoir:
Morton
Rohwer

Harbeck
Patterson
Kohler, Davis
Equation
E = (0.4 + 0.199 w) (ps-pa)
E = 0.5 (1 + 0.1  w) (ps-pa)
E = 0.37 (1 + 0.1  w) (ps-pa)
E = 0.4  {ps C2-exp(-0.2w)l - pa}
E = 0.771 (0.44 + O.llSw) (1.465-0.0186P)
(ps-pa)
E = 0.0599 w (ps-pa)
E = 0.345 (1 + O.lw) (ps-pa)
E = (0.37 +0.1 w) (ps-pa)0'88
Evaporation Rate;
       2
   (q/m  sec)
0.44
0.32
0.23
0.29

0.26
0.070
0.22
0.29
Experimental
Bolz and Tuve
Eq. (2.1-19)
Drying trays
0.15
0.14
E = evaporation rate (inches/day)
w = wind speed (miles/hr)
P, ps, pa in inches Hg.
                                           -16-

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     expressions do not account for the ambient temperature, except through
     its influence on vapor pressures, or for the reservoir size.   Both of
     these factors are accounted for in eqs. (2.1-18) and (2.1-19).   Under
     these circumstances, it is not expected that the agreement between the
     empirical expressions and eqs. (2.1-18) and (2.1-19) to be better than a
     factor of 2.

2.2  Vapor Dispersion
          The vapor from instantaneous flashing (puff) and from continuous
     vaporization or evaporation (plume) moves in the direction of the wind
     and disperses by diffusion into the atmosphere.   The dispersion is assumed
  -   to follow a Gaussian distribution for short travel times (a few minutes
     to one hour).   That is, an individual puff may or may not be well-described
     by a Gaussian formulation, but an ensemble of puffs is assumed to disperse
     in a Gaussian function.  This diffusion model is applicable only to the
                                                        *-
     vapors whose densities do not differ greatly from that of air (Slade).
     The wind is assumed to be in the direction from the source of spill to
     the control room air intake.   It should be noted that topological variations
     of the terrain between the source and receptor are ignored in this treatment.

2.2.1  Instantaneous Puff Release
          The diffusion equation for an instantaneous puff with a finite initial
     volume and a receptor at the air intake is given by the following equation
     (Yanskey, et al., 3-2; Slade, p. 115):
                                     -17-

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x(x, y, z, h) =
                 / 9
                 (2rt
                                          -  exp { - 1
                                                   + yl_ 1
                                                     O 2J
{ exp! _ 1
                             J
                                     exp
                                     1
                                     1
(2.2-1)
Where     x = concentration (g/m )
          Q = source strength (g) = m
     °XI' °YI* CTZI  = adJusted standard deviations of the puff concentration
     in the horizontal-along-wind (X), horizontal  cross-wind (Y),  and  vertical
     cross-wind directions (Z), respectively  (m).
     x, y, z = distances from the puff center in the X, Y, and Z directions,
     respectively (m).  z is also the effective above-ground elevation of the
     receptor, e.g., the fresh-air intake of a control room.
     h = effective above-ground elevation of the source.
To account for the initial volume of the puff, it is assumed that
2
   =
2
   '
                -2
                 XI
                -2
                 YI  * °o
     rr
   -  °XI   =   oYI
and letting x = XQ - ut
     °o =
                      3/2 _ 31/3
(2.2-2)
(2.2-3)
(2.2-4)
(2.2-5)
(2.2-6)
(2.2-7)
where
     o  = initial standard deviation of the puff (m)
      o
     aXI'  °YI*  °ZI = standard deviation of puff concentration in the
                                     -18-

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where:    k •  panicle  size multiplier
          N •  number of disturbances  per year
        P1 •  erosion potential corresponding to  the  observed  (or  probable)
              fastest Bile of wind  for  the  1th period between  disturbances.
     The particle  size Multiplier  (k) for Equation 4-3 varies with
aerodynamic particle size, as follows:

           AERODYNAMIC PARTICLE SIZE MULTIPLIERS  FOR  EQUATION 4-3.

                 <30 urn    <15 urn    <10 urn    <2.5  un
 urn    <15 urn    <1D urn
JoO57T
                                                 0.2
     This distribution of particle size within the <30 urn fraction 1s
comparable to the distributions reported for other fugitive dust sources
where wind speed 1s a factor.  This 1s Illustrated, for example. 1n the
distributions for batch and continuous drop operations encompassing a
number of test aggregate materials (see AP-42 Section 11.2.3).
     In calculating emission factors, each area of an credible surface
that Is subject to a different frequency of disturbance should be treated
separately.  For a surface disturbed dally, N • 365/yr, and for a surface
disturbance once every 6 no, N - 2/yr.
     The erosion potential function for a dry, exposed surface has the
following fora:

                      P • 58 (u* - u*)» * 25 (u* - u*)
                                                                     (4-4)
                      P » 0 for u* 5 uj

where:  u* » friction velocity (m/s)
        u£ • threshold friction velocity (m/s)
     Table 4-2 presents the erosion potential function in matrix form.
Because of the nonlinear form of the erosion potential function, each
erosion event must be' treated separately.
                                  4.7

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TABLE 4-2.  EROSION POTENTIAL FUNCTION
«..
•/•
0.2
0.4
0.6
0.8
.0
.2
.4
.6
.8
2.0
2.2
2.4
2.6
2.8
3.0


0
7
19
36
37
83
114
149
188
233
282
336
394
457
525


0
0
7
19
36
37
83
114
149
188
233
282
336
394
457


0
0
0
7
19
36
57
83
114
149
188
233
282
336
394


0
0
0
0
7
19
36
57
83
114
149
188
233
282
336


0
0
0
0
0
7
19
36
57
83
114
149
188
233
282
P <«

0
0
0
0
0
0
7
19
36
57
83
114
149
188
233
/•^)

0
0
0
0
0
0
0
7
19>
36
37
83
114
149
188


0
0
0
0
0
0
0
0
7
19
36
57
83
114
149


0
0
0
0
0
0
0
0
0
7
19
36
57
83
114


0
0
0
0
0
0
0
0
0
0
7
19
36
57
83


0
0
0
0
0
0
0
0
0
0
0
7
19
36
37


0
0
0
0
0
0
0
0
0
0
0
0
7
19
36
                  4-8

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      Equations 4-3 and 4-4 apply only to dry, exposed materials with
 Halted  erosion potential.  The resulting calculation 1s valid only for a
 tloe  period as long or longer than the period between disturbances.
 Calculated  enlsslons represent Intermittent events and should not be Input
 directly Into  dispersion models that  assune steady state emission rates.
      For uncrusted surfaces, the threshold friction velocity  1s best
 estimated from the dry aggregate structure of the soil.   A  simple hand
 sieving  test of surface soil (adapted from a laboratory  procedure
 published by W.  S.  Chepll*)  can be used to determine the mode of the
 surface  aggregate  size distribution by Inspection of relative sieve catch
 amounts, following the procedure specified 1n Section 6.  The threshold
 friction velocity  for erosion can be  determined  from the mode of the
 aggregate size distribution, as described  by Gillette.'°  This conversion
 1s also  described  1n Section 6.
      Threshold friction velocities  for several surface types  have been
 determined  by  field measurements  with  a portable  wind  tunnel.i°-»J   These
 values are  presented 1n Tables  4-3  and 4-4  for Industrial aggregates and
Arizona  sites.   Figure 4-2 depicts  these data graphically.
     The fastest mile of wind for the  periods between disturbances may be
obtained  from  the monthly  LCD summaries  for  the nearest reporting weather
 station  that 1s  representative  of the  site  1n question.'-  These  summaries
report actual  fastest mile values for  each day of  a  given month.  Because
the erosion potential  1s a highly nonlinear  function of the fastest mile,
mean values of the  fastest mile are Inappropriate.   The anemometer heights
of reporting weather stations are found  1n Reference 15, and  should be
corrected to a 10 m reference height using Equation  4-2.
     To  convert  the fastest mile  of wind 
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     TABLE 4-3.  THRESHOLD  FRICTION VELOCITIES—INDUSTRIAL AGGREGATES
Threshold wind


Material
Overburden*
Scoria (roadbed
•ateHal)*
Ground coal*
(surrounding coal
Pile)
Uncrusted coal pile*
Scraper tracks on
coal pile**6
Fine coal dust on
concrete padc
Threshold
friction
velocity,
n/s
1.02
1.33
0.55


1.12
0.62
0.54

velocity at
Roughness
height,
on
0.3
0.3
0.01


0.3
0.06
0.2

10 m
actual
21
27
16


23
15
11

(a/s)
fcf,.
19
25
10


21
12
10


Ref.
7
7
7


7
7
12

*Westem surface coal «1ne.
°Llghtly crusted.
CEastern power plant.
                                  4-10

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         TABLE 4-4.  THRESHOLD FRITION VELOCITIES—ARIZONA SITES"
Location
Threshold
friction
velocity,
  •/sec
Roughness
 height,
   (a)
  Threshold
wind velocity
   •t  10 B.
    •/sec
Mesa - Agricultural site          0.57
Glendale - Construction site      0.53
Narlcopa - Agricultural site      0.58
Yona - Disturbed desert           0.32
Yuma • Agricultural site          0.58
Algodones - Dune flats            0.62
Yuna - Scrub desert               0.39
Santa Cruz River, Tucson          0.18
Tucson - Construction site        0.25
AJo • Nine tailings               0.23
Hayden - Nine tailings            0.17
Salt River. Mesa                  0.22
Casa Grande - Abandoned           0.25
  agricultural land
              0.0331
              0.0301
              0.1255
              0.0731
              0.0224
              0.0166
              0.0163
              0.0204
              0.0181
              0.0176
              0.0141
              0.0100
              0.0067
                  16
                  15
                  14
                   8
                  17
                  18
                  11
                   5
                   7
                   7
                   5
                   7
                   8
                                  4-11

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Fof narrowly «l»ed, finely divided materials only
• —1
A00'*0*l* ••*•
dlilrlbiillon mod* n' U«MM»H




Gravel ^



	 	 __

Coarsa
Sand H

Fine
Sand "

X-
03

02

•
di
w
005


001
(In) (mm) (cnVs)

0
7
• .6
6
4
3
-
2
_
1
05
t
01
002

-
-
-
-
-

-

-
-
-

ISO
"S""-"**
IM***!.*,*.
U«— —^.
100 C-1.TJ_1
a**«<»4tt.


ssrr*^
so f^S3*«i"


0
                 Figure 4-2.  Scale of  threshold friction velocities.

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     This assumes a typical roughness  height  of  0.5  on for open terrain.
Equation 4-5 Is restricted to  large relatively flat  piles  or exposed  areas
with Uttle penetration -Into the  surface wind layer.
     If the pile significantly penetrates the surface  wind layer (I.e.,
with a helght-to-base ratio exceeding  0.2). It Is necessary to  divide the
pile area Into subareas representing different degrees of  exposure to
wind.  The results of physical •odellng show  that the  frontal face of an
elevated pile 1s exposed to wind  speeds of the sane  order  as  the  approach
wind speed at the top of the pile.
     For two representative pile  shapes (conical and oval with  flat-top,
37 degree side slope), the ratios of surface wind speed (u$) to approach
wind speed (ur) have been derived from wind tunnel studies."  The results
are shown 1n Figure 4-3 corresponding to an actual pile height of 11 •. a
reference (upwind) anemometer height of 10 «, and a pile surface roughness
height (2Q) of 0.5 OB.  The Measured surface winds correspond to a height
of 25 en above the surface.  The  area fraction within each contour pair 1s
specified 1n Table 4-5.
     The profiles of us/ur 1n Figure 4-3 can be used to estimate the
surface friction velocity distribution around.similarly shaped piles,
using the following procedure:                         '       *
     1.  Correct the fastest alle value (u*) for the period of Interest
         from the anemometer height (z)'to a reference height of 10 n
         (uf0) using a variation of Equation 4-2, as follows:

                           «•  .   * in  go/o.oos)
                          U'o " u  In (z/6.6fl5J

         where a typical roughness height of 0.5 en (0.005 •) has been
         assumed.'  If a site specific roughness height 1s available,  1t
         should be used.
     2.  Use the appropriate part of Figure 4-3 based on the pile shape
         and orientation to the fastest mile of wind, to obtain the
         corresponding surface wind speed distribution (U), I.e.,
                                 4-13

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   Flow
, Direction
                    Pile A
Pile B1
                     Pile B2
Pile B3
           Figure 4-3.  Contours of normalized surface wind
                                                            speeds,  us/ur.

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          TABLE 4-5.  SUBAREA  DISTRIBUTION  FOR REGIMES OF us/ur
                       Percent of pile surface area  (Figure 4-3)
Pile subarea       Pile A   '•    Pile Bl        Pile 82        Pile  B3
    0.2a              5533
    0.2b             35             2            28            25
    0.2c                           29
    0.6a             48            26            29            28
   ~0.6b              -            24            22            26
    0.9              12            14            15            14
    1.1                                           3            4
                                   4-15

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      3.   For  any subarea of the pile surface having a narrow range of
          surface wind  speed, use e variation of Equation 4-2 to calculate
          the  equivalent friction velocity (u*). as follows:
                                0.4 u*
                           u* •    K* • 0.10 u*                      (4-8)
     From this point on,  the  procedure  1s  Identical  to  that used  for  a
flat pile, as described above.
     Implementation of the above procedure  1s carried out  1n the  following
steps:
     1.  Determine threshold  friction velocity for credible material of
Interest (see Tables 4-3  and  4-4 or Figure 4-2 or determine from mode of
aggregate size distribution).
     2.  Divide the exposed surface area Into subareas of constant
frequency of disturbance  (N).
     3.  Tabulate fastest mile values (u*) for each  frequency of
disturbance and correct them  to 10 m (ut«) using Equation 4-6.
     4.  Convert fastest  mile values (ut«) to equivalent friction
velocities (u*), taking Into  account (a) the uniform wind exposure of
nonelevated surfaces, using Equation 4-5, or (b) the nonunlfonn wind
exposure of elevated surfaces (piles), using Equations 4-7 and 4-8.
     5.  For elevated surfaces (piles), subdivide areas of constant N Into
subareas of constant u* (I.e., within the Isopleth values of u$/ur 1n
Figure 4-3 and Table 4-5) and determine the size of  each subarea.
     6.  Treating each subarea (of constant N and u*) as a separate
source, calculate the erosion potential (P^) for each period between
disturbances using Equation 4-4 and the emission factor using
Equation 4-3.
     7.  Multiply the resulting emission factor for  each subarea by the
size of the subarea. and  add the emission contributions of all  subareas.
Note that the highest 24-h emissions would be expected to occur on the
windiest day of the year.  Maximum emissions are calculated assuming a
single wind event with the highest fastest mile value for the annual
period.
                                 4-16

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     The  reconnended  emission facto- equation presented above assumes that
 all of  the erosion  potential  corresponding to the fastest mile of wind Is
 lost during the period between disturbances.   Because the fastest mile
 event typically lasts only about 2 Bin,  which corresponds roughly to the
 half-life for the decay of actual  erosion potential,  1t could be  argued
 that the  emission factor overestimates part 1cu late Missions.   However,
 there are other aspects of the wind  erosion process which offset  this
 apparent  conservatism:
     1.   The fastest  Bile  event contains peak winds which substantially
 exceed  the mean value for  the event.
     2.   Whenever the fastest mile event occurs, there are usually a
 number  of periods of  slightly lower  mean wind speed which contain peak
 gusts of  the same order as the fastest mile wind speed.
     Of greater concern 1s the likelihood of  overpredlctlon of wind
 erosion emissions 1n  the case of surfaces disturbed Infrequently 1n
 comparison to the rate  of  crust formation.
 4.1.3  Wind Emissions From Continuously  Active Piles
     For  emissions from wind  erosion of  active storage piles, the
 following total  suspended  part 1cu late (TSP) emission factor equation 1s
 recommended:
                                                                     (4-9)
where:  E • total suspended paniculate emission factor
        s • silt content of aggregate, percent
        p • number of days with ±0.25 am (0.01 in.) of precipitation per
            year
        f • percentage of time that the unobstructed wind speed exceeds
            5.4 m/s (12 mph) at the mean pile height
     The fraction of TSP which Is PM,0 is estimated at 0.5 and 1s
consistent with the PM;-8/TSP ratios for materials handling (Section 4.1.1)
and wind erosion (Section 4.1.2).  The coefficient 1n Equation (4-9) 1s
taken from Reference 1, based on sampling of emissions from a sand and
                                 4-17

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 gravel storage  pile  area  during  periods  when transfer and maintenance
 equipment was not operating.   The factor from Reference 1, expressed 1n
 •ass per unit area per day. 1s wort  reliable than  the factor expressed 1n
 •ass per unit mass of Mterial placed  1n storage,  for reasons stated 1n
 that report.  Note that the coefficient  has  been halved to adjust  for the
 estimate that the wind speed  through the emission  layer at the test  site
 was one half of the  value measured above the top of the piles.  The  other
 terns 1n this equation were added to correct for silt,  precipitation,  and
 frequency of high winds,  as discussed  1n Reference 2.   Equation (4-9)  1s
 rated In AP-42  as C  for application  In the sand and gravel  Industry  and 0
 for other Industries (see Appendix A).
     Worst case emissions from storage pile  areas occur under  dry windy
 conditions.  Worst case emissions  from materials handling  (batch and
 continuous drop) operations may be calculated by substituting  Into
 Equation (4-9)  appropriate values  for  aggregate material moisture content
 and for anticipated  wind  speeds during the worst case averaging period,
 usually 24 h.   The treatment of dry  conditions for vehicle  traffic
 (Section 3.0) and for wind erosion (Equation. 4-9), centering around
 parameter p. follows the  methodology described 1n Section 3.0.  Also, a
 separate set of none11mat1c correction parameters and source extent values
 corresponding to higher than normal  storage pile activity may  be justified
 for the worst case averaging period*
 4.2  DEMONSTRATED CONTROL TECHNIQUES
     The control techniques applicable to storage piles fall Into distinct
 categories as related to materials handling operations  (Including traffic
 around piles) and wind erosion.   In both cases, the control can be
 achieved by (a) source extent  reduction,  (b) source Improvement related  to
work practices and transfer equipment  (load-In and load-out operations),
and (c) surface treatment.  These  control options are summarized In
Table 4-6.  The efficiency of  these controls ties back to the emission
 factor relationships presented earHer.in this section.
        .          •*
     In most cases, good work practices which confine freshly exposed
material provide substantial opportunities for emission reduction without
 the need for Investment 1n a control application program.  For example,
pile activity,  loading and unloading, can be confined to leeward
 (downwind) side of the pile.  This statement also applies to areas around

                                  4-18

-------
      •   Topsoll  removal:   5.7  kg./^T for pan scrapers
      •   Earthmovlng:       1.2  kg/VICT for pan scrapers
      •   Truck  haulage:   '  2.8  kg/VKT for haul trucks
 PH10  emissions due to Materials  handling and wind  erosion of  exposed  areas
 can be calculated  using the emission factors presented  In Sections 4.0  and
 6.0,  respectively.
 5.1.2 Demolition  Emissions
      For demolition sites, the operations Involved 1n demolishing and
 removing structures from a site  are:
      •   Mechanical or explosive  dismemberment
      •   Debris loading
      •   Onslte truck  traffic
      •   Pushing  (dozing) operations
      5.1.2.1   Dismemberment.   Since no emission factor data are available
 for blasting or  wrecking a building, the  first operation 1s addressed
 through  the use  of the  revised AP-42 nateHals handling equation:3,*
                       Ej - k(0.0016)      1 4                       (5-1)
                                       (?)  '

where   EQ • PM10 emission factor In kg/Mg of material
         k • particle size multiplier'- 0.35 for PH10
         U • mean wind speed In «/s (default • 2.2 m/s)
         M • material moisture content 1n percent (default « 2 percent)
and     EQ • 0.00056 kg/Mg (with default parameters)
     The above factor can be modified for waste tonnage related to
structural floor space where 1 m* of floor space represents 0.45 Mg of
waste material (0.046 ton/ft:).'  The revised emission factor related to
structural floor space (using default parameters) can be obtained by:

                     En • 0.00056 kg/Mg •  °'45 **
                                             •'
                        - 0.00025 kg/m:
                                  5-3

-------
      5.1.2.3  Debris Loading.   Tht Emission factor for debris  loading 1s
 based on two tests  of the filling of  trucks with crushed  limestone  using a
 front-end loader which Is part  of the test basis for the  batch drop
 equation 1n  AP-42,  § 11.2.3.*   The resulting emission  factor for debris
 loading  1s:J
                                            0.45
                      E. *  k(0.029)  kg/Mg
                       *•                      •»
                        •  0.0046 kg/m»
where 0.029  kg/Mg  1s  the average measured TSP emission factor and k 1s the
particle  size multiplier (0.35 for  PM10).
     5.1.2.4 Ons 1te  Truck Traffic.  Emissions from onslte truck traffic
1s generated from  the existing AP-42 unpaved road equation presented 1n
Section 3.0  above. >
      E • 1-7 k  (HjHry)    ((S}                    (5-2)
where    E • PM,0 emission factor 1n kg/vehicle kilometer traveled (VKT)
         k • particle size multiplier • 0.36 for PN10  .
         s « silt content In percent (default • 12 percent)
         S • truck speed 1n km/h (defaglt » 16 kra/h)
         U - truck weight 1n Mg (default • 20 Hg)
         w - number of truck wheels (default • 10 wheels)
         p « number of days with measurable precipitation
             (default « 0 days)

and     ET • 1.3 kg/VKT (with default values)
     The above factor 1s converted from kg/VKT to kg/m* of structural
f-loor space by:J
     £  m   0.40 km   . 1 m3 waste  .    7.65 mi volume    . 1.3 kg
          23 mJ waste   4 m' volume   0.836 m* floor space     VKT
         « 0.052 kg/mi
     5.1.2.5  Pushing Operations.  For pushing (bulldozer) operations, the
AP-42 emission factor equation for overburden removal at Western surface
                                  5-4

-------
 coal  mines can be used.'  Although this equation actually relates to par-
 tlculate <15 umA, 1t would be expected that the PM10 emissions from such
 operations would be generally comparable.   The AP-42 dozer equation 1s:
                                                                         ,
                              P        (M)1'4
where    Ep • PM,0  emission rate 1n kg/h
         S • silt  content of surface material  1n percent
 «
              (default « 6.9 percent)
         M • moisture content of surface material  1n  percent
              (default • 7.9 percent)
and      Ep • 0.45  kg/h (with default parameters)

     Finally. PH,0 emissions due to wind erosion of exposed areas can be
calculated as discussed 1n Section 6.0.  In general,  these emissions are
expected to be minor  as compared to other sources.
5.1.3  Mud/Dirt Carryout Emissions
     Finally, the  Increase 1n emissions on paved roads due to mud/dirt
carryout have been developed based on surface  loading measurements at
eight sites.*  Tables 5-2 and 5-3  provide these emission factors in terms
of gm/vehlcle pass which represent PM;0 generated over and above the
•background*  for the  paved road  sampled.  Table 5-2 expresses the emission
factors according  to  the volume  of traffic entering and  leaving the site
whereas Table 5-3  expresses  the  same data according to type of
construction.
5.2  DEMONSTRATED  CONTROL TECHNIQUES   •
     As discussed  above,  similar generic open dust sources "exist at both
construction and demolition  sites.  Therefore, similar types of controls
would also apply.  In this  section, a' discussion 1s provided on the
various tecnnlques available  for the control of open dust sources
associated with construction  and demolition.  Detailed Information on
control efficiency, Implementation cost, etc., will be presented in
Section 5.3 below.
                                  5-5

-------
        TABLE  5-2.  EMISSIONS INCREASE UE) BY SITE TRAFFIC VOLUME* '
Sites with >25
Particle
size .
fraction"
<-30 uB
<10 UB
<2.5 u>
Mean,
X
52
13
5.1
Standard
devia-
tion, 0
28
6.7
2.6
veh1de/d
Range
15-80
4.4-20
1.7-7.8
Sites
Mean,
X
19
5.5
2.2
with <25 veh1cle/d
Standard
devia-
tion, v
7.8
2.3
0.88
Range
14-28
4.2-8.1
1.6-3.2
*aE expressed In g/veh1c1e pass.
Aerodynamic diameter.
TABLE -5-3.
Particle
size
fraction0
<-30 uB
<10 uB

Mean,
X
65
16
<2.5 uffl 6.3
EMISSIONS
Conmerdal
Standard
devia-
tion, 0
39
9.3
3.6
INCREASE* (AE)

Range
15-110
4.2-25
1.6-9.7
BY CONSTRUCTION TYPE*

Mean,
X
39
10
3.9
Residential
Standard
devia-
tion, o
»•
22
5.4
2.1

Range
10-72
2.8-19
1.1-7.3
*iE expressed 1n g/vehlcle pass.
"Aerodynamic diameter.
                                   5-6

-------
                        6.0  OPEN AREA WIND EROSION

     Oust emissions My be generated by wind erosion of open agricultural
 land or exposed ground areas on public property or within an Industrial
 facility.
     With regard to estimating part1culate emissions from wind erosion of
 exposed surface material, site Inspection can be used to determine the
 potential for continuous wind erosion.  The two basic requirements for
 wind erosion are that the surface be dry and exposed to the wind.  For
 example. 1f the contaminated site lies 1n a swampy area or 1s covered by
 unbroken grass, the potential for wind erosion 1s virtually nil.  If. on
 the other hand, the vegetative cover 1$ not continuous over the exposed
 surface, then the plants are considered to be nonerodlble elements which
 absorb a fraction of the wind stress that otherwise acts to suspend the
 Intervening soil.
     For estimating emissions from wind erosion, either of two emission
 factor equations are recommended depending on the credibility of the
 surface material.  Based on the site survey, the exposed surface must be
 placed 1n one of two credibility classes described below.  -The division
 between these classes 1s best defined 1n terms of the threshold wind speed
 for the onset of wind erosion.
     Nonhomogeneous surfaces Impregnated with nonerodlble elements
 (stones, clumps of vegetation, etc.) are characterized by the finite
 availability ("limited reservoir") of credible material.  Such surfaces
 have high threshold wind speeds for wind erosion, and part 1culate emission
 rates tend to decay rapidly during an erosion event.   On the other hand,
 bare surfaces of finely divided material such as sandy agricultural soil
 are characterized by an "unlimited reservoir" of credible, particles.  Such
 surfaces have low threshold wind speeds for wind erosion,  and partlculate
emission rates are relatively time independent at a given wind speed.
     For surface areas not covered by continuous vegetation, the
classification of surface material as either having a "limited reservoir"
or an "unlimited reservoir' of erodlble surface particles Is determined by
estimating the threshold friction velocity.  Based on analysis of wind
erosion research, the dividing line for the two credibility classes 1s a


                                  6-1

                                                   Preceding page blank

-------
 threshold  friction velocity of about 50 on/s.   This somewhat arbitrary
 division 1s based on the observatlcr. that highly credible surfaces;
 usually corresponding to sandy surface soils that are fairly deep,  -have
 threshold  friction velocities  below 50 cn/s.  Surfaces with  friction
 velocities larger than 50 cn/s tend to be composed of aggregates  too large
 to be eroded «1xed 1n with a snail  amount of credible Material  or of
 crusts  that are  resistant to erosion.'
     The cutoff  friction velocity of 50 on/s corresponds  to  an  ambient
 wind speed of  about 7 •/$ (15  mph), measured at a height  of  about 7 m.   In
 turn, a specific value of threshold friction velocity for the credible
 surface Is needed for either wind erosion emission factor equation
 (model).
     Crusted surfaces are regarded  as  having a 'limited reservoir"  of
 credible particles.   Crust thickness and strength should  be  examined
 during  the site  Inspection,  by testing with  a  pocket  knife.   If the crust
 1s more than 0.6 cm thick and  not easily crumbled between the fingers
 (modulus of rupture  >1  bar), then the  soil may be considered non-
 erodlble.   If  the crust thickness Is less than 0.6 cm or  1s  easily
 crumbled,  then the surface should be treated as having a  limited  reservoir
 of credible particles.   If a crust  1s  found  beneath a loose  deposit, the
 amount  of  this loose deposit,  which constitutes the limited erosion
 reservoir,  should be carefully estimated.
     For uncrusted surfaces, the threshold friction velocity  1s best
 estimated  from the dry  aggregate structure of  the soil.  A simple hand*
 sieving test of  surface  soil 1s highly desirable  to determine the mode of
 the surface  aggregate size distribution by Inspection of relative sieve
 catch amounts, following  the procedure specified  1n Figure 6-1.  The
 threshold  friction velocity for erosion can  be  determined from the mode of
 the aggregate  size distribution, following a relationship derived by
 Gillette (1980)  as shown  1n Figure  6-1.-'
     A more  approximate basis  for determining  threshold friction velocity
would be based on hand  sieving with just  one sieve, but otherwise follows
 the procedure  specified  in Figure 6-2.   Based on  the relationship
developed  by Blsal and  Ferguson (1970),  1f more than 60 percent of the
                                  5-2

-------
I

CJ
                 u
                 01
                 U
                 o
I


u
•r-

U.

•a

*o

i/»
•i
                      IOOO
      lop
                        10
                                                                                   I  «••*••!
                           0.1
                                  I                    10



                     Aggregate  Size Distribution Mode (m)
100
                  Figure 6-1.  Relationship of threshold friction velocity to size distribution node.

-------
     FIELD PROCEDURE FOR DETERMINATION OF THRESHOLD FRICTION VELOCITY*

1.  PREPARE A NEST OF SIEVES WITH THE FOLLOWING OPENINGS:  4 on, 2 •».
    1 on. 0.5 on. 0.25 m.  PLACE A COLLECTOR PAN BELOW THE BOTTOM SIEVE
    (0.25-MB OPENING).

2.  COLLECT A SAMPLE REPRESENTING THE SURFACE LAYER OF LOOSE PARTICLES
    (APPROXIMATELY 1 on IN DEPTH FOR AN UNCRUSTEO SURFACE). REMOVING ANY
    ROCKS LARGER THAN ABOUT 1 on IN AVERAGE PHYSICAL DIAMETER.  THE AREA
    TO BE SAMPLED SHOULD NOT BE LESS THAN 30 Oi x 30 ou

3.  POUR THE SAMPLE INTO THE TOP SIEVE (4-on. OPENING). AND PLACE A LID ON
    THE TOP.

4.  ROTATE THE COVERED SIEVE/PAN UNIT BY HAND USING BROAD SWEEPING ARM MO-
    TIONS IN THE HORIZONAL PLANE.  COMPLETE 20 ROTATIONS AT A SPEED JUST
    NECESSARY TO ACHIEVE SOME RELATIVE HORIZONTAL MOTION BETWEEN THE SIEVE
    AND THE PARTICLES.     -                                  '

5.  INSPECT THE RELATIVE QUANTITIES OF CATCH WITHIN EACH SIEVE AND
    DETERMINE WHERE THE MODE IN THE AGGREGATE SIZE DISTRIBUTION LIES.
    I.E.. BETWEEN THE OPENING SIZE OF THE SIEVE WITH THE LARGEST CATCH AND
    THE OPENING SIZE OF THE NEXT LARGEST SIEVE.
•ADAPTED FROM A LABORATORY PROCEDURE PUBLISHED BY W. S. CHEPIL (1952).*
                               Figure  6-2.
                                    6-4

-------
soil passes a  1-an  sieve,  the  "unlimited  reservoir" node! will  apply;  If
not, the 'United reservoir" model iill apply.*  This relationship has
been verified  by Gillette  (1980)  on  desert  soils.*
     If the soil contains  nonerodlble elements which are too  large to
Include In the sieving  (I.e.,  greater than  about 1 OB In diameter), the
effect of these elements must  be  taken Into account by Increasing  the
threshold friction  velocity.   Marshall (1971) has employed wind tunnel
studies to quantify the Increase  1n  the threshold velocity for  differing
kinds of nonerodlble elements."   His results are depicted In  terms  of  a
graph of the rate of corrected to unconnected friction velocity versus Lc
(Figure 6-3).  where 1^ 1s  the  ratio  of the  silhouette area of the
roughness elements  to the  total area of the bare loose soil.  The
silhouette area of  a nonerodlble  element  Is the projected frontal area
normal to the  wind  direction.
     A value for LC Is obtained by marking off a l-m x l-« surface area
and determining the fraction of area, as  viewed from directly overhead,
that 1s occupied by nonerodlble elements.  Then the overhead area should
be corrected to the equivalent frontal area; for example. If a spherical
nonerodlble element 1s half embedded 1n the surface,  the frontal area  1s
one-half of the overhead area.  Although  1t 1s difficult to estimate Lc
for values below 0.05, the correct1on-to-fr1ct1on velocity becomes less
sensitive to the estimated value of  Lg.
     The difficulty 1n estimating Lg also Increases for small  nonerodlble
elements.  However, because small nonerodlble elements are more likely to
be evenly distributed over the surface, 1t 1s usually acceptable to
examine a smaller surface area, e.g., 30 cm x 30 cm.
     Once again, loose sandy soils fall into the high credibility
("unlimited reservoir") classification.  These soils  do not promote crust
formation, and show only a brief effect of moisture addition by
rainfall.  On the other hand, compacted soils with a  tendency for crust
formation fall Into the low ("limited reservoir") credibility group.   Clay
content In soil, which tends to promote crust formation,  1s evident from
crack formation upon drying.
                                  6-5

-------
                        2     3   45*7891   .    2    J   4S67I9I
                                                                          2    3  4  3 • 7 B4l
TJ
 OJ
4J
 U
 O»
(U
     o
     c
     13
              10
                            Figure 6-3.  Increase in threshold friction  velocity with LC.

-------
      The  roughness height,  z0,  which  1s  related to the  size  and  spacing of
 surface roughness  elements, 1s  needcu to convert the friction  velocity to
 the equivalent wind speed at the typical weather station  sensor  height of
 7 • above the surface.   Figure  6-4  depicts  the  roughness  height  scale  for
 various conditions of ground cover.*   The conversion to the  7-9  value  1s
 discussed below.
 6.1   ESTIMATION OF EMISSIONS
 6.1.1 'Limited* Erosion Potential
      In the  case of surfaces characterized  by a *11i1ted  reservoir" of
 credible  particles, even the highest  Kan atmospheric wind speeds are
 usually not  sufficient to sustain wind erosion.  However, wind gusts Bay
 quickly deplete a  substantial portion of the erosion potential.  Because
 erosion potential  has been  found  to Increase rapidly with Increasing wind
 speed, estimated emissions  should be  related to the gusts of highest
 •agnltude.
      The  routinely measured Meteorological  variable which best reflects
 the Magnitude  of wind gusts 1s the fastest Mile.  This quantity represents
 the wind  speed corresponding to the whole Mile of wind Movement which  has
 passed by the  1-«1  contact  anemometer 1n the least amount of tine.  Dally
Measurements of the fastest Mile  are presented  1n the monthly Local CUma-
tologlcal Data (LCD)  summaries.   The LCD summaries May be obtained from
the National Climatic Center, Ashevllle, North Carolina.  The duration of
the fastest mile,  typically about 2 «1n  (for a fastest «1le of 30 nph).
matches well with  the half  life of the erosion process, which ranges
between 1 and  4 irln.  It should be noted, however, that peak winds can
significantly  exceed  the dally fastest «1le.
     The wind  speed profile  1n the surface boundary layer 1s found to
follow a  logarithmic  distribution:
                         u(2) • o  1n {- (z "  V                   <6-^
             -*.                        o
where:    u •  wind  speed, on/s
         u* •  friction velocity,  cm/s
                      %
          z •  height  above  test surface, cm
        _Z0 •  roughness height, en
        0.4 •  von (Carman's  constant, dlmenslonless
                                  6-7

-------
           High Rise Buildings
           (30+Floors)
            Suburban
            Medium Buildings
            (Institutional)
   u
  O
      Suburban
      Residential Dwellings  '
              Wheat Field.
  O-
              Plowed Field
                                   Zo (cm)
                                     1000
             Natural Snow







*





BOO
600
100
—200—
100 .
—80
—60
-40
-20
io
™^*o»
mt^^^3 •
— 2
1.
— 0.
— 0
— 0.
— 0.
0.
.0—
.0—
.0—
.oJ
.0
0—
0—
0
8—
4 	
2
1
                                              Urban Area
                                              Woodland Forest
Grassland
Figure 6-4. Roughness  heights for various surfaces.

                       6-8

-------
     The friction velocity (u+)  1r  a measure  of wind shear stress on the
credible surface, as  determined  from the  slope  of the logarithmic velocity
profile.  The  roughness  height (zo)  1s  a  Measure of the roughness of the
exposed surface  as determined from  the  y-Intercept of the  velocity
profile. I.e., the height  at which  the  wind speed 1s zero.  These
parameters are Illustrated 1n Figure 6-5  for  a  roughness height of 0.1  on.
     Emissions generated by wind erosion  are  also dependent on the
frequency of disturbance of the  credible  surface because each time that a
surface 1s disturbed.  Its  erosion potential 1s  restored.  A disturbance 1s
defined as an  action which results 1n the exposure  of fresh surface
material.  On  a  storage  pile, this would  occur  whenever aggregate material
1s either added  to or  removed from the  old surface.   A disturbance of an
exposed area may also  result from the turning of  surface material to a
depth exceeding  the size of the  largest pieces  of material present.
     The emission factor for wind-generated partleulate emissions from
mixtures of credible and nonerodlble surface material  subject to
disturbance may  be expressed In units of  g/m*-yr  as follows:
                                             N
                       Emission  factor  •  k.  J    P<                  (6-2)

where:   k • particle  size multiplier
         N • number of disturbances per year
        Pj • erosion potential corresponding to the observed (or probable)
             fastest mile of wind for the 1th period between disturbances,
             g/m'
     The particle  size multiplier (k) for Equation 6-2 varies with
aerodynamic panicle size, as follows:

          AERODYNAMIC  PARTICLE'SIZE MULTIPLIERS FOR EQUATION 6-2
                    <3D tun    <15 urn     <10 um     <2.5  K»
                    TTo      57?        575       572
                                  6-9

-------
AatTHMK nc
                        to*
                                                         torn
                                                Srceo AT Z
                                                •Sreeo  AT tOm
         Figure 6-5.   Illustration of  logarithmic  velocity profile.

-------
     This distribution  of  particle s1?^ within  the <30 urn fraction 1s
 comparable to the distributions reported for other fugitive dust sources
 where wind speed 1s • factor.  This 1s Illustrated, for example. 1n the
 distributions for batch and continuous drop operations enconpasslng a
 number of test aggregate materials (see AP-42 Section 11.2.3).
     In calculating emission factors, each area of an credible  surface
 that Is subject to a different frequency of disturbance should  be treated
 separately.  For a surface disturbed dally, N • 365/yr. and for a surface
    «
 disturbance once every  6 mo, N • 2/yr.
     The erosion potential function for a dry,  exposed surface  has the
 following font:
              P • 58 (u* - u*)» * 25 (u* - u*)
              P • 0 for u* s uj

where:   u* • friction velocity (•/$)
        u£ • threshold friction velocity (•/$)
     Because of the nonlinear fora of the erosion potential function, each
erosion event must be treated separately.
     Equations 6-2 and 6-3 apply only to dry, exposed materials with
limited erosion potential.  The resulting calculation 1s valid only for a
time period as long or longer than the period between disturbances.
Calculated emissions represent Intermittent events and should not be Input
directly Into dispersion models that assume steady state emission rates.
     For uncrusted surfaces, the threshold friction velocity Is best
estimated from the dry aggregate structure of the soil.  A simple hand
sieving test of surface soil (adapted from a laboratory procedure
published by W. S. Chepll*) can be used, to determine the mode of the
surface aggregate size distribution by Inspection of relative sieve catch
amounts, following the procedure specified 1n Figure 6-2.  The threshold
friction velocity for erosion can be determined from the mode of the
aggregate size distribution, as described by Gillette.*  This conversion
1s presented 1n Figure 6-1.
                                 6-11

-------
     Threshold  friction velocities s'or several surface types have been
determined by field measurements with a portable wind tunnel.  These
values are presented 1n Tables 6-1 and 6-2 and Figure 6-6.
     The fastest «11e of wind for the periods between disturbances Bay be
obUlned froo the Monthly LCD suonaHes for the nearest reporting weather
station that 1s representative of the site In question.7  These summaries
report actual fastest mile values for each day of a given month.  Because
the erosion potential 1s a highly nonlinear function of the fastest alle.
wan values of the fastest mile are Inappropriate.  The anemometer heights
of reporting weather stations are found 1n Reference 8, and should be
corrected to a 10 • reference height using Equation 6-1.
     To convert the fastest mile of wind (u*) from a reference anemometer
height of 10 m to the equivalent friction velocity (u*), the logarithmic
wind speed profile Bay be used to yield the following equation:
                              u* • 0.053 uto                         (6-4)

where:   u* • friction velocity (•/$)
        uf0 • fastest mile of reference anemometer for period between
              disturbances (a/s)
     This assumes a typical roughness -height of 0.5 on for open terrain.
Equation 6-4 Is restricted to large relatively flat areas with little
penetration Into the surface wind layer.
     Implementation of the above procedure 1s carried out 1n the following
steps:
     1.   Determine threshold friction velocity for erodlWe material  of
         Interest (see Tables 6-1 and 6-2 and Figure 6-6 or determine from
         mode of aggregate size distribution).
     2.   Divide the exposed surface area  Into subareas of constant
         frequency of disturbance (N).
     3.   Tabulate fastest mile values (u*) for each frequency of
         disturbance and  correct them to  10 m (uto) using Equation 6-5.
                                 6-12

-------
                  TABLE 6-1.  THRESHOLD DICTION VELOCITIES
•

Material
Overburden*
Scoria (roadbed
material)*
Ground coal
(surrounding coal
pile)
Uncrusted coal p11ea
Scraper tracks on
coal pile*'6
Fine coal dust on
concrete padc
Threshold
friction
velocity
(•/$)
1.02
1.33

0.55


1.12
0.62

0.54


Roughness
height
0.3
0.3

0.01


0.3
0.06

0.2


Threshold

wind


velocity at 10 n (m/s)
Z0 • Actual Zg
21
27

16


23
15

11

• 0.5 cm
19
25

10


21
12

10

Ref.
2
2

2


2
2

3

fwestem surface coal  «1ne.
"Lightly crusted.
 Eastern power plant.
                                       6.13

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           TABLE 6-2.   THRESHOLD FRICTION VELOCITIES—ARIZONA SITES
Location
Threshold
 friction
velocity,
  •/sec
                                               Roughness
                                               height.
Threshold
   velocity
at  10 m.
  •/sec
Mesa - Agricultural site          0.57
Glendale - Construction site      0.53
Marlcopa - Agricultural site      0.53
Yuaa • Disturbed desert           0.32
YUM - Agricultural site          0.58
Algodones - Dune flats            0.62
YUM - Scrub desert               0.39
Santa Cruz River, Tucson          0.18
Tucson - Construction site        0.25
Ajo - Nine tailings               0.23
Nayden - Mine tailings            0.17
Salt River. Mesa                  0.22
Casa Grande - Abandoned           0.25
  agricultural land
              0.0331
              0.0301
              0.1255
              0.0731
              0.0224
              0.0166
              0.0163
              0.0204
              0.0181
              0.0176
              0.0141
              0.0100
              0.0067
  16
  15
  14
   8
  17
  18
  11
   5
   7
   7
   5
   7
   8
                                       6-14

-------
                       For narrowly sited. (Inety divided malarial* only
I
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                                                                        - ISO
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                                                                                             ri«tlwMp«Mii

                                                                                             •41M4
                                                                        Jfl
                                         Figure 6-6.   Scale of  threshold friction velocities.

-------
     4.  Convert fastest  mile values  (uf0)  to equivalent friction
         velocities  (u*), using Equation 6-4.
     5.  Treating each subarea (of constant H and u*)  as a separate
         source, calculate the erosion potential (Pj)  for each  period
         between disturbances using Equation 6-3 and the emission factor
         using Equation 6-2.
     6.  Multiply the resulting emission factor for each subarea  by the
         size of the subarea. and add the emission contributions  of all
         subareas.  Note  that the highest 24-h ealsslons Mould  be expected
         to occur on the  windiest day of the year.  Max1BUD emissions  are
         calculated assualng a single wind event with the highest  fastest
         •He value for the annual period.
     The recoonended emission factor equation presented  above assumes  that
all of the erosion potential corresponding to the fastest rile of wind 1s
lost during the period between disturbances.  Because the fastest mile
event typically lasts only about 2 Bin. which corresponds roughly to the
half-life for the decay of actual erosion potential. It could be argued
that the emission factor overestimates partlculate emissions.  However,
there-are other aspects of the wind erosion process which offset this
apparent conservatism:
     1.  The fastest mile event contains peak winds which substantially
         exceed the mean value for the event.
     2.  Whenever the fastest mile event occurs, there are usually a
         number of periods of slightly lower mean wind speed which contain
         peak gusts of the same order as the fastest mile wind speed.
     Of greater concern 1s the likelihood of overpred1ct1on of wind
erosion emissions 1n the case of surfaces disturbed Infrequently 1n
comparison to the rate of crust formation.
6.1.2  "Unlimited'  Erosion Potential
     For surfaces characterized by an "unlimited reservoir* of credible
particles,  partlculate emission rates are relatively time Independent  at a
given wind speed.  The technology currently used for predicting
agricultural wind erosion 1n the  United States  1s based on variations  of
the Wind Erosion Equation.*;,»»   This prediction system uses erosion loss
estimates that are  Integrated over large fields  and long-time scales to
                                 6-16

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                              7.0  AGRICULTURE

      Fugitive dust from agricultural  operations  Is  suspected of
 contributing significantly  to the  ambient  part1culate  levels of many
 agricultural counties.   Such  agricultural  operations Include (a) plowing,
 (b)  disking, (c)  fertilizing,  (d)  applying herbicides  and  Insecticides,
 (e)  bedding, (f)  flattening and  fining beds, (g) planting,  (h) culti-
 vating,  and (1) harvesting.   These operations can be generlcally
 classified as soil  preparation,  soil maintenance, and  crop harvesting
 operations.  As discussed In Section 6« dust Missions are also generated
 by wind  erosion of  bare  or  partially vegetated soil.  This section will
 focus on emissions  fron  both wind  erosion  and agricultural tilling opera-
 tions that are designed  to  (a) create the  desired soil structure  for the
 crop seed bed and (b) to eradicate weeds.
 7.1   ESTIMATION OF  EMISSIONS
 7.1.1 Tilling
      The mechanical tilling of agricultural land Injects dust particles
 Into the ataosphere as the soil Is loosened or turned under by plowing.
 disking,  harrowing, one-way1ng, etc.  AP-42 presents a predictive emission
 factor equation for the estimation of dust emissions from agricultural
 tilling:*

                          E  -  k(5.38)(s)«-« kg/ha   •
                         E • k(4.80)(s)o*«  Ib/acre

where:  s • silt content (percent)  of surface soil  (default value of
            18 percent)
        k • particle size multiplier (dimenslonless)
The particle size multiplier,  k Is  given as 0.21  for PM,O.   The above
equations are based solely on  field testing information cited 1n AP-42.
Silt content of tested soils ranged from 1.7 to 88  percent.
                                  7-1

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 7.1.2  Hind Erosion
     The technology currently used for predicting agricultural wind
 erosion 1n the United States 1s based on variations of the Wind  Erosion
 Equation.».»  This prediction system uses erosion loss estimates that  are
 Integrated over large fields and long time scales to produce average
 annual values.
   * 7.1.2.1  Simplified Version of Wind Erosion Equation.  Presented
 below 1s a procedure for estimating windblown or fugitive dust emissions
 from agricultural fields.  The overall approach and much of the  data have
 been adapted from the wind erosion equation, which was developed as the
 result of nearly 40 yr of research by the U.S. Department of Agriculture
 to  predict topsoll losses from agricultural fields.
     Several simplifications have also been Incorporated during the
 adaptation process.  The simplified format 1s not expected to affect
 accuracy 1n Its present usage,  since wind erosion estimates using the
 simplified equation are almost  always within 5X of those obtained with the
 original USOA equation.  Most of the Input data are not accurate to ±5X.
     7.1.2.1.1  Windblown dust  equation.  .The modified equation 1s of the
 form:

                             E « kalKCL'V                           (7-1)

where:    E • PMi0 wind erosion  losses of  tilled fields,  tons/acre/yr
         k • 0.5, the estimated fraction  of TSP which 1s PM10
         a • portion of total wind erosion losses that would be measured
             as suspended part1culate, estimated to be 0.025
         I  « soil credibility,  tons/acre/yr
         K • surface roughness  factor, d1mens1on1ess
         C • climatic factor, dlmenslonless
        L'  • unsheltered field  width factor,  dlmenslonless
        V  » vegetative cover factor, dlmenslonless
     As  an  aid In understanding the mechanics of this equation,  "I" may be
thought  of  as the basic credibility of a  flat,  very  large, bare field 1n a
climate  highly conducive to wind erosion  (I.e.. high wind speeds and
temperature with little precipitation) and 1C, C. L', and V  as  reduction
                                  7-2

-------
 factors for • ridged surface, a c11mat« less conducive to wind erosion,
 smaller-sized fields, and vegetative cover, respectively.
      The sane equation can be used to estimate emissions from:  (1) a
 single field, (2) a medium-sized area such as a valley or county, or
 (3) an entire AQCR or state.   Naturally,  more generalized Input data must
 be used for the larger land areas, and the accuracy of the resulting
 estimates decreases accordingly.
      7.1.2.1.2  Procedures for compiling  Input data.  Procedures for
 quantifying the five variable factors 1n  Equation (7-1)  are explained 1n
 detail below.
      Soil Credibility.  I.   Soil  credibility by wind Is a function of the
 amount of credible fines  In the  soil.  The largest  soil  aggregate size
 normally considered to  be  erodlble 1s approximately 0.84 ma equivalent
 diameter.  Soil credibility.  I.  1s related to the percentage of  dry
 aggregates greater than 0.84  mm  as shown  1n Figure  7-1.   The percentage  of
 nonerodlble aggregates  (and by difference  the amount of  fines) 1n a  soil
 sample can be determined experimentally by a standard dry sieving
 procedure, using a No.  20  U.S. Bureau of Standards  sieve  with 0.84-mm
 square openings.'                                                       .
      For areas  larger than can be  field sampled for soil  aggregate size
 (e.g..  a county)  or In  cases where  soil particle  size distributions  are
 not available,  a representative  value of  I  for use  1n the windblown  dust
 equation can  be obtained from the predominant soil  type(s) for farmland  1n
 the area.   Measured credibilities of  various  soil textural classes are
 presented  1n  Table  7-1.
      If  an area Is too  large to be accurately represented by a soil  class
 or by  the  weighted  average of several  soil  classes,  the map  In Figure 7-2
 and the  legend  In Table 7-2 can be used to  Identify major soil deposits
 and average soil credibility on a national  basis.  Other  soil maps are
 available  from*the Soil Conservation Service branch of the U.S. Department
 of Agriculture.
     Values of  I obtained from Figure 7-1, from Table 7-1. or from soil
maps can be substituted directly into Equation (7-1).
                                  7-3

-------
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Figure 7-1.  Soil credibility as a function of particle size.
                           7-4

-------
TABL- 7-1.  SOIL ESSOIBILITY F33. WRIuL'S
          SOIL TEXTURAL CLASSES
Predominant soil textural class
Sand*
Loamy sand*
Sandy loan*
Clay
SUty clay
Loam
Sandy clay loam8
Sandy clay*
S1lt loam
Clay loan
Silty clay loam
sm
Credibility, I,
tons/acre/yr
220
134
36
86
86
»
56
56
56
47
47
28
38
*Very fine, fine, or Medium sand.
                 7-5

-------
                                                      CtNtBAt SOIL MAP Of THC UNtTtO STATES
                                         Figure 1-2.  Generalized soli map  of  the United States.
i.

-------
               TABLE 7-2.  LEG-NO rop SOIL MAP IN ?IGUR£ '-2
Al, A2            Season*!!./ wet soils with subsurface clay accumu-at'c-
A3- AS            Cool or cold soils with subsurface clay accumulation
A6- A8            Clays
A9. AID           Burnt clay soils
Al)- A13          Dry clay soils with some cementation
01- 06            Arid soils with clay and alkali or caroonate
                  accumulation
El                Poorly.drained loamy sands
E2                Loamy or clayey alluvial deposits
E3- £8            Shallow clay loan deposits on bedrock
E9                Loamy sands 1n cold regions
E10. E12          Loamy sands 1n warn regions
Ell. E13, E14     Loamy sands 1n warn, dry regions
HI, H2            Wet organic soils; peat and muck
II                Ashy or amorphous soils 1n cold regions
12                Infertile soils with large amounts of amorphous material
13                Fertile soils of weathered volcanic ash
14                Tundra; frozen soils
15, 16            Thin loam surface horizon soils
                                                           *-
17                Clay loams in cool regions
18- 110           Wide varying soil material with some clay t'or
111               Rocky soils shallower than 20 in, to oeorocK
112               Clay loams in warm, moist regions
113               Clay loams In cold regions
                                •(continued)
                                  7-7

-------
LLL/dl401-7at. D. 3
                                 LE •»-» 'Continued
   114               Clay  loams  1n temperate climates
   Ml- M4            Surface loam horizon underlain by clay
   MS                Shallow surface loams with no underlying clays
   M6- MS            Surface loamy soils
   M9- M14           Semlarld loams or clay loams
   M15. M16          Dry loams
   01, 02            Clays and sandy clays
   SI- S4            Sandy, clay, and sandy clay loams
   Ul                Wet silts with some subsurface clay accumulation
   U2- U6            S1lty loams with subsurface clay accumulation
   U7                Dry silts with thin subsurface clay accumulation
   VI- V2            Clays and clay loams
   V3- V5            SUty clays
   XI- X5            Barren areas, mostly rock with some Included soils
                                     7-3

-------
      Surface Roughness Factor.  K.  Th!s factor accounts  for the  resistance
 to wind erosion provided  by  ridges and furrows or  large  clods  In the
 field.  The surface roughness factor. K.  1s a function of  the  height and
 spacing of the ridges, and varies fron 1.0 (no reduction)  for  a  field'with
 a saooth surface to a minimum of 0.5 for  a field with the  optimum ratio  of
 ridge height (h) to ridge spacing (w).
      The relationship between K and h*/w  1s shown  1n Figure 7-3.  The
 value of K to be used 1n  Equation (7-1) should be rounded  to the  nearest
 0.1 because of the large  variations Inherent In ridge measurement data.
 In cases where there are  extreme variations of h or w within a field.
 determination of the K value should be United to either 0.5 for a ridge
 surface or 1.0 for an unrldged surface.
      For county or regional areas, K can best be determined  as a function
 of crop type, since field preparation techniques are relatively uniform
 for a specific crop.  Average K values of coonon field crops are shown 1n
 Table 7-3.  When the K (or L* or V)  factors are based on crop type,
 separate calculations of windblown dust emissions must be made for each
major crop In the survey area.  This  procedure Is explained and
demonstrated later 1n this presentation.        '          -
     Climatic Factor.  C.   Research has Indicated that the rate of soil
movement by wind varies directly as the cube of wind velocity and
Inversely as the square of soil  surface moisture.  Surface moisture 1s
difficult to measure directly, but precipitation-evaporation Indices can
be used to approximate the amount of  moisture 1n soil surface particles.
Therefore,  readily available climatic data can provide a quantitative
Indicator of relative  wind erosion potential  at  any geographic location.
     The  C factor has  been calibrated using the  climatic conditions at the
site of much of the research—Garden  City, Kansas—as the standard base
(C « 1.00).   At any other geographic  location,  the  C factor for use 1n
Equation  (7-1)  can be  calculated as:
                                          u'
                              C - 0.345 -=—r                       (7-2)
                                         (PE)
                                 7-9

-------
ff
o
CO

CO
IU
u

ti-
ff

CO
                                                  INCHES
             Figure 7-3.  Determination of surface  roughness  factor.
                                      7-10

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TASLi T-3.   VAL'JES *" *.,  '..  AMH v FOP. CCMMCN  -H.D CHOPS
Crop
Alfalfa
Barley
Beans
Corn
Cotton
Grain hays
Oats
Peanuts
Potatoes
R1ce
Rye
Saf flower
Sorghum
Soybeans
Sugar beets
Vegetables
Wheat
• K
1.0
0.6
0.5
0.6
0.5
0.8
0.8
0.6
0.8
0.8
0.6
1.0
0.5
0.6
0.6
0.6
0.6
. L. ft
1000
2000
1000
2000
20CO
2000
2000
1000
1000
1000
2000
2000
2000
2000
1000
500
200C
V, "3/JCrs
30CO
11CO
:so
5:0
2:0
1250
1250
250
400
1000
1250
- 1500
300
250
100
100
1350
                          Ml

-------
 where:   W ««ean annual wind velocity, -in mph, corrected  to  a standard
              height  of 30 ft
        PE *  Thomthwalte's precipitation-evaporation  Index
           •  0.83 (sun of 12 monthly ratios of precipitation  to actual
              evapotransplratlon)
     Monthly  or seasonal climatic factors can be estimated from
 Equation (7-2) by substituting the Man wind velocity  of the  period  of
 Interest for  the  Man annual wind velocity.  The annual PE value 1s  used
 for all calculations of C.
     CIlMtlc factors have been computed froa Heather Bureau data for many
 locations throughout the country.  Figure 7-4 1s a up showing annual
 climatic factors  for the USA.  C values for use 1n Equation (7-1) may be
 taken from appropriate maps like this when preparing regional emission
 surveys.  For emission estimates covering smaller areas. Equation (7-2)
 may be used to obtain C.
     Unsheltered  Field Width Factor.  L'.   Soil  erosion across a field 1s
 directly related  to the unsheltered width along the prevailing wind
 direction.  The rate of erosion 1s zero at the  windward edge  o.f the field
 and Increases approximately proportionately with distance downwind until.
 If the field  1s large enough,  a maximum'rate of soil  movement 1s reached.
     Correlation between the width of a field and Its rate of erosion 1s
 also affected by the soil  credibility of  Us surface:  the more credible
 the surface, the shorter the distance 1n  which  maximum soil movement 1s
 reached.  This relationship between the unsheltered width of  a field (L),
 Us surface credibility (IK),  and Us relative  rate of soil erosion (L1)
 1s shown graphically 1n Figure 7-5.   If the curves  of Figure  7-5 are used
 to obtain the L1  factor for the windblown dust  equation,  values for the
 variables I and K must already be known and an  appropriate value for L
must be determined.
     L 1s calculated as  the  distance  across the  field 1n the  prevailing
wind direction minus the distance from the windward edge of the field that
 1s protected from wind erosion by a barrier.  The distance  protected by a
barrier 1s equal  to 10 times the height of the  barrier, or 10  H.  For
example, a row of 30-ft  high trees along  the  windward side  of  a field
reduces the effective width  of the field  by 10  x  30 or 300  ft.  If the
                                 7-12

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                                           SMT|$
ANNUAL CLIMATIC FACTOR C
ORIGINAL DRAWING 4-17-68. 0. V. ARMBRUST.
ARK.. IA., KV., LA.. TCNN.. W. VA. ADDED
11-24-71. N. P. WOODRUFF.
                          Figure  7-4.  Climatic factor used In wind erosion equation.

-------
Figure 7-5.   Effect of field length on relative  emission rate.

-------
 prevailing wind direction differs significantly  (more than 25 degrees)
 from perpendicularity with the field, L should be  Increased to account  for
 this additional distance of exposure to the wind.  The distance across  the
 field. L  1s equal to the field width divided by the cosine of the angle
 between the prevailing wind direction and the perpendicularity to the
 field:
     For aultlple fields or regional surveys, measurement and calculation
of L values become unwieldy.  In region-wide emission estimates, average
field widths should be used.  Field width 1s generally a function of the
crop being grown, topography of the area, and the amount of trees and
other natural vegetation 1n or adjacent to the faming areas that would
shelter fields from erosive winds.  Since the windblown dust calculations
are already split Into Individual crop type to accurately consider
variations 1n K by crop, average L values have also been developed by
crop; they are presented 1n Table 7-3.  These values are representative of
field sizes In relatively flat terrain devoid of tall natural vegetal ton,
such as found 1n large areas of the Great Plains.  The L values 1n
Table 7-3 should be divided by 2 1n areas with moderately uneven terrain
and by 3 1n h11ly areas.  Additionally, the average field width factors
should be divided by 2 to account for wooded areas and fence thickets
Interspersed with farmland.
     Vegetative Cover Factor. V.  Vegetative cover on agricultural fields
during periods other than the primary crop season greatly reduces wind
erosion of the soil.  This cover most commonly Is crop residue, either
standing stubble or mulched Into the soil.  The effect of various amounts
of residue, V, 1^ reducing erosion 1s shown quantitatively In Figure 7-6,
where IKCL' 1s the potential annual soil loss (1n tons/acre/yr) from a
bare field, and V  Is the fractional amount of this potential loss which
results when the field has a vegetative cover of V, In lb of a1r-dr1ed
residue/acre.   Obviously, the other four variables 1n Equation (7-1)— I,
K, C, and L'— must be known before V can be determined from Figure 7-6.
                                 7-15

-------
I
t-t
O»
                             Figure 7-6.   fffect  of vegetative cover on relative emission rate.

-------
     The amount of vegetative cover en a single field can DS esce-tainec
by collecting and weighing clean res'Jje from a representative plot sr oy
visual comparison with calibrated onotographs.  The weight obtained by
either measuring method oust then be converted to an equivalent weight of
flat small-grain stubble before entering Figure 7-6, since different crop
residues vary 1n their ability to reduce wind erosion.  Detailed
descriptions of the Measuring methods or conversion procedures are tso
complex for this presentation.  Interested readers are referred to the
USOA for these descriptions.
     The residue left on a field when using good soil conservation
practices 1s closely related to the type of crop.  Table 7-3 presents
representative values of V for common field crops-when stubble or mulch 1s
left after the crop.  These values should be used 1n calculating windblown
dust emissions unless a knowledge of local farming practices indicates
that some Increase or decrease Is warranted.  Note that three of the five
variables 1n the windblown dust equation are determined as functions of
the crop grown on the field.
     7.1.2.1.3  Summary.  The estimated emissions 1n tons/acre/yr nay now
be calculated for each field or group of fields as the product of the five
variables times the constant "a* estimated to be 0.025, and the particle
size multiplier for PH10 estimated to be 0.5.
     For regional emission estimates, the acreage 1n agriculture should be
determined for each jurisdiction (e.g.,' county) toy croc.  "I" and "C"
values can be determined for Individual jurisdiction, with the remaining
three .variables being quantified as functions of crop type.  The emission
calculations are best performed 1n a tabular format such as the one snown
in Table 7-4.  The calculated emissions from each crop are summed to get
agricultural wind erosion emissions by jurisdiction and these are totalec
to get emissions for this source category for the entire region.
  .  7.1.2.1.4  appropriate Usage of Results.  Inherent variabilities  in
the many parameters used in the windblown dust equation cause the results
to be less accurate than emission estimates for most other sources.
However, the rough estimates provided by the proposed procedure are better
than not considering this source at all 1n particulate emission Inventory
                                  7-17

-------
                   •   TABLE 7-4.  CALCULATION  SHEET FOR ESTIMATION OF DUST FROM MIND EROSION
Juris-     I,C.                          K,        L,      V,      L'.     V .     E, •»  Tot.ll
diction    Based on    Climatic                   Surface   Field   Veget.  Length Vegot. alKC- Kmi:isi<>i>:
(County)   Soil Typo   Factor    Crop    Acres    Roughness Length  Cover   Factor Factor I.'V*  hy rrnii

                                Alfalfa
                                Oarlcy
                                Deans
                                Corn
                                Cotton
                                Potatoes
                                Sorghum
                                Soybeans
                                Sugar
                                 Deets
                                Vcgets.
                                Wheat
                                Etc'                                                                _
                                   -    •                                                   TotnT
_-- -	—	•	_^_^^^^-_J^^-^^-^^^—  i .^^—,^^m^tm mt  —•,^^__^^^^^^         ^ » -. .

                               (List of
                                Crops
                                Crown in
                                Juris-
                                diction)
                                                                                           Tot.il

-------
work.  Inclusion of this source category, possibly with some qualifying

statement as to Its relative accuracy, gives an Indication of Its

contribution to regional air quality.

     The estimation procedure 1s not Intended for use In predicting

emissions for short t1«e periods, nor can 1t be used 1n determining

edsslon rates for enforcement purposes.
     7.1.2.2  Hew Wind Erosion Prediction Technology.  New technology for

prediction of agricultural wind erosion Is currently being developed by

the U.S. Department of Agriculture.   This undertaking was recently

described by L. J. Hagen as follows.'

      Currently, the U.S. Department of Agriculture 1s taking a
      leading role 1n combining erosion science with data bases and
      computers to develop what should be a significant advancement
      1n wind erosion prediction technology.  In 1986 an Initial
      group composed of Agricultural Research Service (ARS)  and Soil
      Conservation Service (SCS) scientists was formed to begin
      development of a new Wind Erosion Prediction  System (HEPS).
      Additional scientists are now  being added to  the group to
      strengthen specific research and technology development
      areas.  The objective of the project 1s to develop replacement
      technology for the Wind Erosion Equation.

        •  The primary user of wind  erosion prediction technology  Is
      the USDA Soil  Conservation Service, which has several  major
      applications.   First, as a part of the periodic National
      Resource Inventory, 1t collects data at 300,000 primary
      sampling points, and at central locations,  calculates  the
      erosion losses occurring under current land use practices.
      The  analyzed results are used  to aid In developing regional
      and  national policy.

           Second, SCS does conservation planning of wind erosion
      control practices to assist farmers and ranchers In meeting
      erosion tolerances.   Implementation of adequate conservation
      plans preserves land productivity and reduces  both onsfte and
      offslte damages.  Conservation planning requires a prediction
      system that will operate on a  personal  computer and produce
      answers 1n a relatively short  time.   In addition,  WEPS  must
      serve as a communication cool  between conservation planners
      and  those who  implement the plans.

           Various users  also undertake project planning  in which
      erosion prediction  1s used to  evaluate erosion and  deposition
      1n areas Impacted by the project.   In this  aopHcation, more
      time and resources  may be expended than in  conservation
      planning to collect  input data and make analyses.   Project
                                 7-19

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       planning 1s typically carried  out by mult1d1sc1pHnary teams
       Including field personnel w.^-  collect  needed  Input data.

           Other users of wind erosion  prediction technology
       represent a wide range of problem areas.  Often  their  problems
       will require development of additional models to supplement
       WEPS 1n  order to obtain answers of Interest.  Some of  these
       diverse  problem areas Include  evaluating new erosion control
       techniques, estimating long-term  soil productivity changes,
       calculating onslte and offslte economic costs of erosion,
       finding  deposition loading of  lakes  and streams,  computing the
       effects  of dust on add rain processes, determining Impact of
       management strategies on public lands, and estimating
       visibility reductions near airports  and highways.

           From the preceding survey of user needs, 1t  1s apparent
       that the prediction technology must deal with a wide range of
       soil types and management factors.  Wind erosion prediction
       technology also must cover a broad range of climatic and
       geographic regions 1n the United States.  The major Impact of
       wind erosion 1s 1n the Great Plains, but credible areas 1n the
       Great Lakes region, the semlarld western United States, and
       windy coastal regions are all affected.

7.2  DEMONSTRATED CONTROL TECHNIQUES

7.2.1  Tilling

     Operational modifications to tilling of the soil  Include the use of

novel  Implements or the alteration of cultural techniques to eliminate
some operations altogether.  All  operational  modifications will  affect

soil preparation or seed planting operations.  Furthermore,  the  suggested

operational modifications are crop specific.   Estimated PM10  efficiencies

for agricultural controls are presented In Table 7-5.
     The punch planter 1s a novel  Implement which might have  applications

for emissions reduction from planting cotton, corn,  and lettuce.  The
punch planter 1s already being used In sugar  beet production. The punch

planter punches a hole and places  the seed Into It,  as  opposed to

conventional  planters  which make  a trough and drop  the  seeds  1n  at a

specified spacing.   The advantage  1s  that punch planters can  leave much of

the surface soil and surface crop  residues undisturbed.  Large-scale use

of the punch planters  would require Initial capital  Investments  by the
farming Industry for new equipment.
                                 7-20

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                        Attachment 6



Excerpts from Superfund Exposure Assessment Manual (EPA88c)
                             66

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                                    EP A/540/1 -« 8/001
                               OSWER Directive 928S.S-1
                                        April 1888
Superfund Exposure Assessment

                Manual
          U.S. Environmental Protection Agency
            Office of Remedial Response
              Washington, DC 20460

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 quantified property values. These data are available
 for  many  chemicals  that  may be present  at
 uncontrolled hazardous  waste sites, and are found in
 various chemical  reference  texts. In cases  where
 chemical data are missing, the analyst must estimate
 the property values. This section  provides equations
 for estimating  certain requisite chemical  properties.
 Comprehensive  guidance for chemical property
 estimation is providdd in reference materials such as
 Lyman et al. (1982). Readily accessible computerized
 systems are available to predict a range of pertinent
 chemical properties. The computerized  Graphic
 Exposure   Modeling System (GEMS),  and  its
 subsystem  CHEMEST.  is an  example.  The EPA
 Office of Toxic Substances in Washington, O.C. has
 developed and is managing this system. Essentially a
 computerized  version of Lyman et al. (1982), it can
 be rapidly  accessed  to estimate  the  chemical
 characteristics necessary for volatilization estimation.

 The user of this manual can  refer  to Farino et al.
 (1983) for a detailed review and evaluation of existing
 equations  for  estimating  volatilization   from
 uncontrolled hazardous  waste  sites. This  report
 presents a survey of available air  release  models for
 volatile  substances  and a critical analysis of the
applications  and limitations of each.

(1) Landfills Without Internal Gas Generation
Equation 2-3  can  be  used  to  estimate volatile
releases from covered  landfills containing  toxic
materials alone, or toxic  materials segregated from
other landfilled nonhazardous wastes. Equations 2-4
through  2-7 are  used  to calculate certain  input
variables that  are  required to  apply  Equation  2*3.
 Farmer  et  al. (1978)  developed an equation to
estimate the effectiveness of  various  landfill cover
types and depths in controlling volatile releases'. This
equation, based .on  Pick's First Law  of steady state
diffusion, assumes that diffusion into the atmosphere
occurs  at a plane surface  where  concentrations
remain constant  It ignores biodegradation,  transport
in water, adsorption, and  production of landfill  gas.
Diffusion of  the toxic vapor through the soil cover is
the controlling factor. It  also assumes that there is a
sufficient mass of toxicant  in  the  landfill so  that
depletion of the  contaminant will not reduce the
emission rate.

Equation 2-3,  simplified by  Farmer  et al. (USEPA
 1980b), incorporates a  number of assumptions  (see
 Farino et al. 1983 for a complete discussion), such as
completely dry  soil  (worst  case)  and  zero
  • Although computerized dispereion modeing can be uMd to
  obtam contaminant release me*, tt is primarily a  tool tor
  determine contaminant atmospheric fat*. Thus, rater to
  Chapter  3. Environmental Fate  Anaiyaia.  tor detailed
  discussions ol a* dispersion models applicable to unoontroaad
  hazardous waste tacMea.
concentration of  volatilizing  material  at  the  soil
surface.  Shen (1981) converted  Farmer's  simplified
equation for calculating the vapor flux rate to a form
that provides  a  toxic  vapor emission  rate  by
multiplying  the  basic equation by the  exposed
contaminated surface area. In addition. Shen modified
the equation to allow calculation  of the volatilization
rate of a specific component of the overall toxic
mixture by multiplying by the weight fraction of the
component in the  mixture.  However,  as pointed out
by  Farino et al. (1983),  a  more  accurate  approach
would be to multiply by the mole fraction of the toxic
component  in the buried mixture.  Thus.  Farmer's
equation, as modified by Shen (1981) and  Farino et
al. (1983). is:*
    Ei=Di
                                       (2-3)
where
A
Pt
Mi
•mission rate of component i. (g/sec).
diffusion coefficient of component i  in  air.
(cm2/sec).
saturation vapor concentration of component
i, (g/cm3).
exposed area. (cm?).
total soil porosity, (dimensionless).
mole fraction of toxic component i  in  the
wast«,(gmote/gmole).
effective depth of soil cover, (cm).
Note that total soil porosity, rather than air-filled sofl
porosity, is  used in  this equation. The presence  of
water in a soil cover will tend to decrease the flux rate
of a volatile compound by effectively decreasing the
porosity,  and also  by  increasing  the  geometric
complexity of the sofl pore system  (because  water
adheres to soil particles), thus effectively increasing
the  vapor  path  (USEPA 1980b).  Farmer  et  al.
suggest however, that when using their equation  to
design a  landfill  cover,  the total  porosity value be
used (USEPA 1980b), thereby designing for the worst
case (i.e.. dry conditions). In most instances, it wiP be
appropriate  to apply  this same worst-case logic  to
the analysis of  volatilization release from  landfilled
wastes, assume that  landfill cover soils are dry. and
use a value for total porosity  in Equation 2-3. It is
recognized, however,  that there may be situations
where it can be  shown that cover soils exist in a wet
condition  more  often  than in  a dry one.  In  these
cases, the  air-filed sol porosity (Pa) may  be more
appropriate, and this value can be substituted  for  Pt
in Equation 2-3 when analyzing volatilization release.

N not providec in existing literature. DI, a compound's
diffusion coefficient (required for the  above equation),
can be  calculated by Fuller's Method (Perry and
Chilton 1973):

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        0.001TtTO-
              sfe
                           MW
       T
 MWt;MWa
      P.
ZVi;£Va
                                         (2-4)
                  absolute temperature. (*K).
                 .molecular weights of toxic
                  substance and air (28.8).
                  respectively, (g/mole).
                  absolute pressure, (atm).
                  molecular diffusion volumes  of
                  toxic substance  and air (20.1).
                  This is  the  sum of the atomic
                  diffusion  volumes   of  the
                  compound   components.
                  (cm3/moie).
To estimate  short-term (maximum)  release rates.
use  a value for  the  temperature  that reflects the
expected  summer maximum temperatures.  Annual
average temperatures should be  used  to  initially
estimate long-term (average) release rates. This
initial estimated  long-term  release  value  will  be
revised as described in Section 2.3.3 to develop final
long-term  release  estimates.
Relevant atomic  diffusion  volumes for use
estimating D{ are (Perry and Chiton 1973):
                                            in
 C •  16.5
 H -  1.98
 0 «  5.48
 N «  5.69
         Cl
         Br
         F
         S <
             19.5
             35.0
             25.0*
             17.0
Aromatic ring     • -20.2
Heterocyclic ring  • • 20.2
Table 2-3 presents diffusion coefficients that have
been calculated for a variety of compounds, some of
which may be present at abandened sites.

An alternative method (Shen 1981) for approximating
DI involves the identification of a compound listed in
Table 2-3 that has a molecular weight and molecular
diffusion volume (calculated) similar to those of the
toxic  substance  under  evaluation.  The unknown
diffusion coefficient can then be calculated using:
0,=]
where
    D*
           MW,
                                          (2-5)
        diffusion coefficient of the compound to
        be estimated from the known D'.
        diffusion coefficient of a compound that
        can be found in the table, the molecular
                                                            weight and atomic diffusion, volume of
                                                            which are close to that of the unknown.
                                                     MW*   •  molecular weight  of  the selected
                                                                compound D'.
                                                      MW(   «  molecular weight of the compound to
                                                                be estimated.
                             Total sofl porosity,
                             (USEPA 19806):
                                                                      can be calculated as  follows
                                                                                           (2-6)
                                                  where
                                                            total soil porosity, (dimensionless).
                                                            sod bulk density.* (g/cm3): generally
                                                            between 1.0 and 2.0 g/crn3.
                                                            particle density, (g/cm3): usually 2.65
                                                            g/cm3 used for most mineral material.
For  estimation,  Pt can  be  assumed  to be
approximately  0.55 for  dry,  non-compacted soils,
and about 0.35 for compacted soils. This same value
(0.35) is also  appropriate for use as a  generic air-
filled soil  porosity (Pa)  when  analyzing  the
volatilization release from soils with  a high moisture
content  (Shen  1981). Alternatively,  the local  Soil
Conservation Service office  can be contacted to
obtain  she-specific  estimated air-filled soil  porosity
values for specific locations.

Saturation  vapor concentration,  C.j, can be
determined by (USEPA 1980b):
                                                                                           (2-7)
                                                  where
                                                       Ctf   »  saturation  vapor concentration  of
                                                                component i, (g/cm3).
                                                         p   •  vapor pressure of the chemical," (mm
                                                                Hg).
                                                      MWj   •  mole weight of component i, (g/mole).
                                                         R   »  molar gas constant. (62.361 mm Hg-
                                                                cm3/mole-*K).
                                                         T   «  absolute temperature. (K).

                                                  Again,  use maximum  summer  temperatures  to
                                                  estimate short-term release and annual average
                                                  temperatures to initially  estimate long-term release.
  •Th» value • from Snan (1881).
                                                   • Valuee tor aoi buk danafty for (pacified locations can be
                                                   obtained from ttte U.S. Sol Conaervaton Service, 8oM* S Fie
                                                   data DAM.
                                                   • If th» vapor pretture of • chemicel under consideration ia not
                                                   available in standard reference teat, eatimaie it ai deacnoad in
                                                   Lyman et al.  (1882).
                                                 17

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