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Authorized Limits for Fernald Copper Ingots

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Authorized Limits for Fernald Copper Ingots ANL/EAD/TM-73 Authorized Limits for Fernald Copper Ingots N. Frink,* S. Kamboj, J. Hensley, and S.-Y. Chen prepared by Environmental Assessment Division, Argonne National Laboratory, 9700 South Cass Avenue, Argonne, Illinois 60439 September 1997 prepared for U.S. Department of Energy, Ohio Field Office, Miamisburg, Ohio, and Fernald Site Office, Fernald, Ohio fJTIOM Of IT 'Frink is affiliated with Trinity Environmental Systems, Inc., Cincinnati, Ohio. This report is printed on recycled paper. DISCLAIMER This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or use- fulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any spe- cific commercial product, process, or service by trade name, trademark, manufac- turer, or otherwise does not necessarily constitute or imply its endorsement, recom- mendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof. DISCLAIMER Portions of this document may be illegible in electronic image products* Images are produced from the best available original document* CONTENTS ACKNOWLEDGMENTS vi NOTATION vii SUMMARY 1 1 INTRODUCTION 5 2 REGULATORY FRAMEWORK AND POLICY CONSIDERATIONS 7 2.1 Regulatory Framework 7 2.2 Policy Considerations 8 3 DESCRIPTION OF FERNALD COPPER INGOTS 11 3.1 Material Origin and Production Process 11 3.2 Physical Characteristics 12 3.3 Chemical Characteristics 12 3.4 Radiological Characteristics 12 4 DESCRIPTION OF DISPOSITION METHODS 15 4.1 Initial Screening of Alternatives 15 4.1.1 No Action 15 4.1.2 On-Site Disposal 15 4.1.3 Restricted Reuse 16 4.1.4 Decontamination Prior to Release 17 4.2 Unrestricted Release for Recycle 17 4.2.1 Secondary Copper and Product Manufacturing 18 4.2.2 End-Use Applications 18 4.3 Disposal at Off-Site Low-Level-Waste Facility 21 5 DOSE ASSESSMENT 22 5.1 Dose Assessment Methodology 22 5.2 Input Parameters 22 5.3 Dose Estimates for Release Scenarios 24 6 COST ANALYSIS 29 6.1 Off-Site Disposal 30 6.2 Recycle 30 CONTENTS (Cont.) 7 ALARA ANALYSIS 32 8 ADDITIONAL FACTORS 33 8.1 Schedule Impacts 33 8.2 Local Economic Impacts 33 8.3 Institutional Preferences 34 8.4 Local Social Preference 35 8.5 Environmental Impacts 36 8.5.1 Land Disturbance 36 8.5.2 Water Quality Degradation 37 8.5.3 Air Quality Degradation 37 8.5.4 Energy Use 37 9 PREPARATION PRIOR TO RELEASE 39 9.1 DOE Property Management Procedures 39 9.2 Surface Treatment, Decontamination, and Packaging for Transport 39 10 SURVEY AND ANALYSIS METHODS 40 10.1 Existing Survey and Analysis Results 40 10.2 Quality Assurance and Quality Control 40 10.3 Survey and Analysis Prior to Release 41 10.4 Survey and Analysis Documentation 41 11 STAKEHOLDER COORDINATION 42 12 REFERENCES....... 43 APPENDIX: Overview of Secondary Copper Industry 45 FIGURES S.I Comparison of Dose with Existing Release Standards and Dose Limits 3 1 Pathways for Worker and Public Exposures during Copper Ingot Processing 23 2 Cost for Fernald Ingot Disposition Alternatives 31 A.I Flow of Copper Scrap and Refined Copper in the United States 51 TABLES S.I Proposed Authorized Limits for Release of Fernald Copper Ingots 2 1 Crosswalk among Development Document Sections, Handbook Guidance, and Fernald Decision Methodology 9 2 Physical Attributes of Remaining Fernald Copper Ingots 12 3 Chemical Attributes of Fernald Copper Ingots 13 4 Activity Concentration of Radionuclides in Fernald Copper Ingots 14 5 Screening of Disposition Alternatives 16 6 Product Distribution Scenarios 19 7 Initial Radionuclide Concentrations in Fernald Copper 23 8 Partitioning Factors for Fire Refining of Copper 24 9 Worker Exposure Scenarios and Parameters 25 10 Public End-Use Exposure Scenarios and Parameters 26 11 Individual and Collective Doses in Worker Scenarios for Processing Fernald Copper Ingots 27 12 Individual, Collective, and Cumulative Doses for End-Use Product Scenarios for Fernald Copper Ingots 28 13 Basis of Estimate for Disposition Alternative Costs 29 14 Decision Summary Matrix , 34 A.I U.S. Consumption of Copper Products by Major End-Use Market in 1994 48 A.2 U.S. Supply of Products from Wire Mills, Brass Mills, Foundries, and Powder Plants 50 A.3 U.S. Consumption of Copper from Ore and Scrap in 1994 52 A.4 Consumption of Scrap Copper at U.S. Processing Facilities by Grade 53 ACKNOWLEDGMENTS This report was made possible through cooperative efforts of several U.S. Department of Energy (DOE) Program Offices (EM-43, EM-77, and EH-41), the Ohio Field Office, and the Fernald Site Office. In March 1997, EM-43, working with EH-41, published the Draft Handbook for Controlling Release for Reuse or Recycle of Property Containing Residual Radioactive Material. In anticipation of the handbook, the Ohio Field Office requested funding to support a case study implementing the new guidance. The project was funded by EM-77 as one of seven interrelated tasks designed to enhance site-level implementation of pollution prevention, reuse, and recycling initiatives. The Fernald Site Office took the lead role on the project, providing oversight and direction for project activities. The project benefited greatly from the insights and comments provided by DOE personnel, including Pete Yerace (DOE-FN), Don Hodge (DOE-OH), Bob Fleming (EM-43), Stephen Warren (EM-43), and Andy Wallo (EH-41). In addition, the project benefited from interactions with personnel working on the related tasks funded by EM-77, notably Michael Gresalfi (Oak Ridge National Laboratory [ORNL]), Kathy Yuracko (ORNL), Bob Lehrter (Fluor Daniel Fernald), and Jim Wells (Fluor Daniel Fernald). NOTATION The following is a list of the acronyms, initialisms, and abbreviations (including units of measure) used in this document. Acronyms used only in tables or figures are defined in the respective tables or captions. ACRONYMS, INITIALISMS, AND ABBREVIATIONS ALARA as low as reasonably achievable ARAR applicable or relevant and appropriate requirement CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations DEAR U.S. Department of Energy Acquisition Regulation DNFSB Defense Nuclear Facilities Safety Board DOE U.S. Department of Energy EPA U.S. Environmental Protection Agency FEMP Fernald Environmental Management Project FERMCO Fernald Environmental Restoration Management Corp. ISRI Institute of Scrap Recycling Industries IUD intrauterine device LBL Lawrence Berkeley Laboratory LLW low-level waste MDCR maximum detectable count rate MEI maximally exposed individual NLO National Lead of Ohio NPV/LCC net present value of the life cycle cost NRC U.S. Nuclear Regulatory Commission NTS Nevada Test Site OU3 Operable Unit 3 RESRAD residual radioactive material guidelines (computer code) ROD Record of Decision SCQ Sitewide CERCLA Quality Assurance Project Plan CHEMICALS Al aluminum NOX nitrogen oxides As arsenic o oxygen C carbon P 2 phosphorus Cd cadmium Pb lead 6OC0 cobalt-60 Si silicon Cr chromium sulfur dioxide so2 Cu copper 99Tc technetium-99 Fe iron 234u uranium-234 Mg magnesium 2351J uranium-235 Mn manganese 238u uranium-238 Ni nickel Vll UNITS OF MEASURE °c degree(s) Celsius lb pound(s) cm centimeter(s) m meter(s) cm2 square centimeter(s) mm millimeter(s) cm3 cubic centimeter(s) mrem millirem d day(s) oz ounce(s) dpm disintegration(s) per minute pCi picocurie(s) ft2 square foot (feet) ppb part(s) per billion ft3 cubic foot (feet) ppm part(s) per million g gram(s) s second(s) h hour(s) t tonne(s) [metric ton(s)] in. inch(es) ton ton (short) J joule(s) V volt(s) kg kilogram(s) yr year(s) L liter(s) Vlll AUTHORIZED LIMITS FOR FERNALD COPPER INGOTS by N. Frink, S. Kamboj, J. Hensley, and S-Y. Chen SUMMARY This development document contains data and analyses to support the approval of authorized limits for the unrestricted release of 591 of copper ingots containing residual radioactive material from the U.S. Department of Energy (DOE) Fernald Environmental Management Project (FEMP). The analyses presented in this document comply with the requirements of DOE Order 5400.5, "Radiation Protection of the Public and the Environment," as well as the requirements of the proposed promulgation of this order as 10 CFR Part 834. The document was developed following the step-by-step process described in the Draft Handbook for Controlling Release for Reuse or Recycle of Property Containing Residual Radioactive Material.1 Potential alternatives for disposition of the copper ingots were screened to identify appropriate alternatives for in-depth analysis. Alternatives initially considered included long- term storage, on-site and off-site disposal, restricted reuse, and unrestricted release for recycling. Two alternatives were selected for in-depth analysis: (1) unrestricted release for recycling in the secondary copper industry, and (2) off-site disposal as low-level waste. To support the development of authorized limits, the following analyses were completed: description of the copper ingots; definition of the proposed and alternative disposition methods; dose assessment; cost analysis; and ALARA analysis (to keep exposure "as low as reasonably achievable" [ALARA]). To develop authorized limits for release, dose assessments for the "actual and likely" and the "worst plausible" release scenarios were conducted. The actual and likely release scenario involves recycle of the ingots at a secondary copper refinery and use of the recycled copper in electrical wiring and plumbing tube in residential applications. This scenario results in estimated doses to the maximally exposed individual (MEI) of less than 0.02 mrem/yr for a worker (slag worker in the copper refinery) and less than 0.0008 mrem/yr for a member of the general public (household member drinking tap water).
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