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REVIEW OF DRAFT FINAL REPORT FOR UPDATE MILDOS-AREA CODE PROJECT,,

Duane W. Schmidt, CHPU.S. Nuclear Regulatory Commission, NMSS/DWM/ URB

April 16,1997

I have reviewed the draft submittal from Argonne National Laboratory for the Update MILDOS-AREA Code contract: Lettw aeport, MILDOS-AREA: An Update with Incorporation ofIn~auLeach Uranium Recovery Technology (Faillace et al.1997). This document was submitted, asthe draft final report for the project, under cover letter dated March 21,1997, to Deborah

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DeMarco at the NRC.

REVIEW OF THE DRAFT FINAL REPORT

Overall, the draft report provides good descriptions of the upgrades to the MILDOS-AREA codeand the example estimation of the source terms for an in situ leach (ISL) uranium recoveryfacility. I have no major comments on the report. However, there are a number of instanceswhere additional clarification is appropriate, or where minor corrections should be made. Theseare described below.

1. Title Page, DateThere is a typographical error in the listed date. The year should be changed to "1997."

2. Page 1, First ParagraphThe second sentence of this paragraph includes a citation of"(Strenge and Bander,1984)."However, this reference has not been listed in the reference list at the end of the report. It shouldbe added.

3. Page 1, Third and Fourth ParagraphsThese two paragraphs briefly describe the uranium extraction processing methods used at ISLfacilities. It may be reasonable to indicate that the description given is one example of theprocessing steps. It is possible that other facilities use or will use somewhat different processes.

4. Page 3, Table 3-1, Value for Bismuth-210The allowable effluent concentration for 21081 of inhalation class W has not been included. Since

210the default inhalation class for Bi is class W, the limiting concentration (which is 40 pCi m'3)must be provided. Based on page 19 of the example MILDOS-AREA output, it appears that thecorrect value was used in the upgrade of the MILDOS-AREA code.

5. Pages 2-3, Allowable Concentration for Radon 222 ProgenyThe text at the bottom of page 2 indicates that the alloiuable concentrations are taken from the

222values currently tabulated 'in 10 CFR 20, Appendix B. However, for Rn, Appendix B does notprovide an equivalent concentration of radon progeny, in units of WL. That is, the concentrationof 0.0011 WL, listed in Table 3-1, is not tabulated in 10 CFR 20, Appendix B. The value of 0.0011

222WL can be obtained by dividing the occupational derived air concentration (DAC) for Rn (forwhich an attemative value is listed as 0.33 WL) by 300. This procedure is described in the text toAppendix B of 10 CFR 20, and was apparently used for developing allowable air effluentconcentrations for other radionuclides in Appendix B. Since the value of 0.0011 WL is notorovided directly by Appendix B, the justification should be provided in the present report.

Review of Draft Final Report for Update MILDOS-AREA Code Project Page 1

9704240181 970421'PDR WASTE EnclosureWPI-3 PDR

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6. Page 3, Section 4.0 I.,

!! would be helpful to the NRC if this brief introductory paragraph also included a statementindicating that the methods described in the foilowing sections (4.1, etc.) are intended to showone calculation method only, and that other methods may be appropriate for particular operatingsites. Such a statement could be somewhat similar to the statement given in Section 5.0, on thebottom of page 9. Also, as suggested in comment 13, it would be helpful to the NRC to have thisadditional statement high|ighted in the text-perhaps by use of italic or bold font.

7. Page 4 and Following, Units NotationIn the list of variables following equation 1, and in many other locations in the report, the units for |variables are expressed using two different notations. Most units are expressed using the 1

forward slash division sign, as in "pCi/g," but some are expressed using. superscripts, as in4" day ." The report would appear more consistent and polished if a single notation was !

consistently used for expressing units of parameters and values. !

8. Page 4, Emanating Powerin the descriptions of variables below equation 1, the emanating power is indicated to be 0.25, I

though the discussion of the choice of value for this parameter comes later in the report, on page7. On page 4, it may be more appropriate to just indicate that the " unit" for emanating power is" fraction," and not include the value to be used.

The same comment also applies to the description of emanating power following equation 3.]

9. Page 5, Explanation of "f' ParameterThe parameter fis described as " fraction of radon source carried by circulating water (0.8)." Fromthis very brief statement, the meaning of the parameteris not clear. Additional explanation shouldbe provided.

Also, similarly to comment 8, it seems inconsistent to include the value to be used for thisparameter at this point in the report. The value to be used should be described later, where otherparameter values are discussed.

10. Pago 7, End of Section 4.2The last paragraph of this section describes radon emanation from materials and the emanatingpower. However, no references have been cited for this information. If specific references havebeen used here. especially for the indicated values of emanating power, the references shouldbe cited.

11. Page 7 First paragraph of Section 4.3The first two sentences of this section (about lack of releases for vacuum dryers and availableinformation on releases for thermal dryers from cperating facilities) contain important statements,for which no references have been cited. it would be helpful to the potential readers of the reportto know where information on these subjects could be found. If specific references have beenused here they should be cited.

12. Page 7, Section 4.3, Second Paragraph, Release of Other RadionuclidesThe point of this paragraph should be the methods to estimate releases of the radionuclidesother than uranium. The paragraph currently only describes activities of these otherradionuclides. It is a simple step to further assume that releases are proportional to activities, sothat the same percentage values can be applied to releases, but this additional step has notbeen described.

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Also, if references are available to support the percentage values described, which are indicated'-

to be based on field measurements, the references should be cited.

13. Page 9, Section 5.0The last sentence of this page is a statement that indicates that the input parameters chosen arenot meant to serve as substitutes for actual site-specific data. It would be helpful to the NRC tohave this statement highlighted in the text-perhaps by use of italic or bold font.

14. Page 10 and Following, Choices of Parameter ValuesAs has been discussed between Argonne National Laboratory (ANL) staff and NRC staff, it was'

expected that the Highland Uranium Project of Power Resources, Inc. (PRI), would provide site-specific data that could be used for parameters for the example source term calculations. TheNRC has just received from PRI a spreadsheet containing some of the desired data (Hildenbrand1997). The spreadsheet is attached as an addendum to this review. These data should be

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reviewed and used as appropriate to modify the parameter choices for the example source termcalculation.

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15. Page 10 and Foi!owing, Units in CalculationsIn the calculation shown at the bottom of page 10, and in many of the other calculations shown inthe remainder of the report, units for parameter values have not been included. The calculationswould be much more easily understood if units were provided in the calculation.

16. Paga 13, Assumptions for Well Field (3)The first full paragraph of this page indicates that the same parameters used for well field (2)could be applied to well field (3). However, since the total volume of water associated with wellfield (3) is greater than that for well field (2), it seems reasonable that the total water flow andthus the purge water flow for well field (3) would be greater than for well field (2).

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17, Minor Typographical or Editorial Errors'

Page 1, third paragraph, third line: "intorduce" and "bicorbonate" are misspelled.

Page 9, title of Section 5.0: Should this title say " . Source Term Calculation..."instead of. Dose Calculation..."?"

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Fage 13, first line of Section 5.5: " filed" should be spelled as " field.",

Pages 19 and 20, references: In this reference list, all authors should be listed. The "et al."abbreviated form is appropriate for the citations within the text, but not for the reference list.

REFERENCES,

Faillace E.R., D.J. LePoire, S.Y. Chen, and Y. Yuan.1997. Letter Report, MILOOS-AREA: An.

Update with Incorporation ofin-Situ Leach Uranium Recovery Technology. Preliminary draftreport, attached to March 21,1997, letter. Environmental Assessment Division, Argonne,

National Laboratory, Argonne, Illinois.

Hildenbrand P.1997. Spreadsheet containing data about the Highland Uranium Project site to beused in estimating source terms for input into the MILDOS-AREA code. Provided<

electronically, on April 14,1997, to D.W. Schmidt, Nuclear Regulatory Commission. Power' Resources, Inc., Highland Uranium Project, Wyoming.

Review of Draft Final Report for Update MILDOS-AREA Code Project Page 3

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ADDENDUM.. , ,

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SITE-SPECIFIC DATA FOR AN ISL FACILITY,

'PROVIDED BY POWER RESOURCES, INC., HIGHLAND URANIUM PROJECT

i;The spreadsheet of site specific data provided by Pcwer Resources, Inc. (Hildenbrand 1997), is

j printed on the following pages. This spreadsheet is shown essentially as it was provided to theNRC, but with minor formatting changes for readability. The original spreadsheet is available as,

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needed, from the uranium Recovery dranco,,

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filename MILDOS,,

SPM/20 SEPT 1996POWER RESOURCES INC |

HIGHLAND URANIUM PROJECT |

MILDOS DAT REQUESTED BY YUCHIEN I"

PEAK YEAR OF PRODUCTION AND RESOTRATION I

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WELLFIELD DURING MI.' . 3 NOTES |YEARS OF PRODUCTION 1989 TO 2005 !

DAYS PER YEAR | 365PEAK AREA /YR MINED, M^2 200000 320 PATTERNS X 6400

FT^2/ PATTERNAVERAGE ORE THICKNESS, M^2 3AVERAGE DEPTH, M 200 600 FTORE POROSITY | 0.27ORE DENSITY, GM/CM^3 2 125 LB/FT^3 |TOTAL FLOW, GPM 8000 320 P WELLS X 25 l

GPM/WELL l

PEAK NUMBER OF P WELLS 320 |

PEAK NUMBER OF 1 WELLS' 640 AVERAGE 2 I WELLSPER P WELL

P WELL FLOW RATE, GPM 25i WELL FLOW RATE 12

SATELLITE IX SYSTEM |

_SATELLITE FLOWRATE, PEAK GPM 8000uCAPACITY OF IX COLUMN, FT^3 250 ACTUAL RESIN

CHARGE; VESSELS 10*

FT DIA,10 FT HEAD TOHEAD

RESIN POROSITYl ?TOTAL IX COLUMNS, PEAK 20TOTAL RESIN PROCESSED / DAY, FT^3 500 4100 LBS U308/ DAY,8

LBS/FT^3 LOADINGIX UNLOADINGS PER DAY 1 1 PAIR OF IX COLUMNS

UNLOADED PER DAYPURGE OR BLEED TO IRRIGATION

TOTAL PURGE, PEAK, GPM 120 1.5% PURGEPURGE RADIONUCLIDES

U-238 pCl/L 214TH-230 pCi/L <0.2

| RA-226 pCl/L 3440RN-222 pCl/L 135,000PB 210 pCl/L 104

RA REMOVAL EFFICIENCY 99.6 3440 pCi/L IN,12 OUT

| RA IN SLUDGEJCl/GM 320I VOLUME OF SLUDGE /YR, M^3 38 assuming 50 cy/yr

WEIGHT OF SLUDGE /YR, M^3 7AVG TIME SLUDGE STORED, DAYS 185 SHIP ONCE PER YEARPOND RADIONUCLIDES TREATED

WASTEWATER|U-238 pCi/L 224,

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TH-230 pCl/L <0.2*.

RA-226 pCi/L 12RN-222 pCi/L

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PB-210 pCi/L 51AREA OF STORAGE RESERVOIR, M^2 51,395 12.7 ACRES AT 50% 1

CAPACITYIRRIGATION | | |

AVG DEPTH OF STORAGE RESERVO! 4.6 AT 50% CAPACITY I

NUMBER OF IRRIGATORS I 2 iTOTAL AREA OF IRRIGATION, M^2 938875 116 acres irrigator No. 2

and assuming irrigator No.3 is 166 acres

TOTAL IRRIGATOR FLOW RATE, GPM 900 FLOW RATE WHENOPERATING. 2 Irrig at450 gpm each

DAYS /YR IRRIGATOR OPERATES 165 six months at 90%efficiency |

SOIL RADIONUCLIDES !

U-238 pCl/L 1.2TH-230 pCl/L not analyzedRA-226 JCl/L 1,3

RN-222 pCi/L 611PB-210 pCi/L not analyzed ;

RADIONUCLlDES MEASURED AFTER 1 YEARS '!WELLFIELD IN RESTORATION |

YEARS FOR RESTORATION 7DAYS OPERATED PER YEAR 365PEAK AREA /YR IN RESTN, M^2AVERAGE ORE THICKNESS, M^2 3AVERAGE DEPTH, M 200ORE POROSITY | 27.00 %ORE DENSITY, GM/CM^3 2TOTAL FLOW, GPM 500PEAK NUMBER OF P WELLS 20PEAK NUMBER OF i WELLS 0P WELL FLOW PATE, GPM 25i WELL FLOW RATE O

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SATELLITE FLOWRATE, PEAK,GPM 500C APACITY OF IX COLUMN, FT^3 500RESlN POROSITY ?TOTAL IX COLUMNS, PEAK 18TOTAL RESIN PROCESSED / DAY, FT^3 500 batch processing - 31 days

between transfers at 500cf - 96 lbs/ day

IX UNLOADINGS PER DAY ?

ITOTAL PURGE, PEAK, GPM 500PURGE RADIONUCLIDES

U-230 pCi/L 5650TH-230 pCl/L <0.2RA-226 pCi/L 971

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RN-222 pCl/L not analyzed.,

PB-210 pCl/L 276,

RA REMOVAL EFFICIENCY 99.3 based on feed 971 - |treated 6.6 i

RA IN SLUDGE, pCl/GM 121 jVOLUME OF SLUDGE /YR, M^3 38 :WElGHT OF SLUDGE /YR, M^3 7 :AVG TIME SLUDGE STORED, DAYS 185 1

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POND RADIONUCLIDESU-238 pCl/L 359TH-230 pCl/L 0.6RA-226 pCl/L 6.6RN-222 pCl/L 126

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PB-210 pCl/L 42'AREA OF STORAGE RESERVOIR, M^2 20,234 assuming 5 acres

I I |AVG DEPTH OF STORAGE RESERVO! 3

NUMBER OF IRRIGATORS | 1

TOTAL AREA OF IRRIGATION, M^2 222578 assuming 55 acresTOTAL IRRIGATOR FLOW RATE, GPM 250DAYS /YR 1RRIGATOR OPERATES 165SOIL RADIONUCLIDES

U-238 pCl/L 1.9i

TH-230 pCi/L not analyzed )RA-226 pCi/L 1.3| ;RN-222 pCi/L not analyzedPB 210 pCi/L not analyzed

RADIONUCLIDES MEASURED AFTER 9 YEARSWELLFIELD DEVELOPMENT

DRILLING DAYS PER YEAR 250MUD PIT DEPTH, M 3 MUD IS FROM

ADDTITIVES ANDNATIVE FORMATION

MUD PIT WIDTH, M 1 ONLY 3 ME IS ORETHICKNESSES

MUD PIT LENGTH, M 4NEW WELLS PER PIT 1

CONCENTRATION IN MUDU-238 pCl/L not analyzedU-234 pCl/L not analyzedTH 230 pCl/L not analyzedRA-226 pCi/L not analyzedRN 222 pCl/L not analyzedPB-210 pCl/L not analyzed

TIME PIT IS OPEN, DAYS 30 PIT IS CLOSED BYBURIAL

CENTRAL PLANT |

RESIN PROCESS RATE SAME AS SATELLITEURANIUM RECOVERY EFFICIENCY 0.999LOADED RESIN RADIONUCLIDES

U 238 pCl/L not analyzedTH-230 pCl/L not analyzed

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RA-226 pCl/L not analyzed.

PB-210 pCl/L not analyzed i

SATELLITE TO PLANT KM 10l DRYER SCRUBBER EFFIECIENCY| PACKAGING SCRUBBER EFFICIENCY ] I

YELLOWCAKE ACTIVITYTH-230

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RA 226~~

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PB C {i

YELLOWCAKE, % U308 92.00 % IN DRIED PRODUCT l| STACK EMMISS:ON DATA !

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L .nat )| conc release rate * * assumes 81.5%

operartionuCi/ml uCl/qt j

yellowcake stack 1.14E-09 4.92E-03

packaging stack 4.33E-10 1.08E-03~

Th 230 i

conc release rate * *

UCl/ml uCi/qt

yellowcake stack 6.34 E-13 2.73E-06

packaging stack 4.33E-13 1.07E-06

Ra-226conc release rate *

uCl/ml uCl/qt

yellowcake stack 3.2E-13 1.38E-06

packaging stack 3.50E-13 8.70E-07~~

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