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The purpose of this document is to provide an index of the software and files used to generate the results and findings documented in Section 4 of the scoping study report on Radiation Signatures relevant to Thorium Fuel Cycles.
Further to our previous safeguards approach for Accelerator Driven Systems, which focused on estimates of fissile material production using relevant proton accelerator systems and corresponding safeguards needs for fuel storage, the subcritical reactor, and spent fuel storage material balances areas, this report is more expansive and considers utilization of ADS for either burning of transuranics or breeding of fissile materials. We find that the recycled fuels likely intended for ADS will be thermally and radioactively hot to such a degree that it is likely reprocessing and fuel fabrication will have to be co - located with the ADS reactor facility to avoid impractical hot fuel transportation issues. As such, we consider in detail the full ADS system to include material balance areas for spent fuel receiving, reprocessing, storage & cooling, fuel fabrication, subcritical reactor area, and waste storage & handling. Furthermore, aqueous - based separation methods like PUREX cannot tolerate the intense heat of the ADS fuels, so pyroprocessing will likely be required. With these considerations, we developed an Enhanced Safeguards Approach for ADS beyond the work done in our first report, and conclude that significant diagnostic development is needed , a nd provide safeguards recommendations. We have also included an appendix regarding some country programs, in particular the Chinese ADANES burner/breeder program a nd the Indian thorium - based breeder program.
ThorCon is developing a thermal thorium / uranium molten salt fueled reactor that uses a fuel salt consisting of NaF - BeF 2 - ThF 4 - UF 4 - UF 3 , which uses 19.75% enriched uranium. It is not a breeder reactor but requires regular additions of fissile material. On-site fuel processing is limited to adding make-up fuel, and adding beryllium to maintain redox balance in the fuel salt. The fluoride salt is an excellent flux that will strip the protective oxygen away from all metal surfaces it contacts. In order to protect the metal surfaces in the primary loop, no free fluorine is allowed. Maintaining a ratio of UF 4 to UF 3 provides a chemical buffer that can absorb any free fluorine released during the fission process before it can harm the structure. Periodic additions of metallic beryllium to the fuel salt will react with UF 4 to form BeF 2 and UF 3 , which will maintain the desired UF 4 /UF 3 ratio. A means to measure the UF 4 /UF 3 ratio is important to maintain the fuel salt in a non-corrosive state and could also provide additional insight into the corrosion behavior and chemical constitution of the system. A promising measurement technique is based on electrochemistry.
The overall objective of this project is to produce a rare earth elements product with greater than 8% rare earth elements from coal-based resources using an economically viable and environmentally benign processing methodology. The objective of the coal processing work will be to acquire appropriate coal feed and produce a viable clean coal product, a concentrated REE feed stream, and a pyrite stream (where available) that can be used to enhance leaching. The objective of the bio-oxidation portion of the project is to utilize bacteria to oxidize sulfide minerals and ferrous ions to ferric ions to accelerate leaching and remove the sulfides to prevent future acid mine drainage and related liabilities. The objective of the solution conditioning work is to remove iron and control leaching solution conditions to facilitate extraction of REEs without significant thorium extraction. The objective of the column leaching work is to engineer/model and simulate heap leaching to demonstrate low-cost extraction of REEs from coal-based resources. The objective of the solvent extraction work is to selectively extract and recover through controlled stripping of REEs that are solubilized through leaching. The objective of the precipitation portion of the project is to recover the REEs from the solvent extraction stripping solutions and dry them to achieve the final product of rare earth elements that is > 8 % REEs. The objective of the technical, economic, and environmental analysis is to determine the overall viability of the processing approach that is demonstrated in this project
The objectives of the vadose modeling for the updated Hanford Site Composite Analysis (CA) are to simulate the flow and transport of water and radionuclide releases from the surface to the water table and to provide radionuclide transfer rates to the CA saturated zone model (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). Water additions include natural recharge and water discharged to the ground as a result of industrial processes associated with Hanford Site operations. Contaminant sources include radionuclides in water discharged to the ground during operations and radionuclides disposed “dry” in solid waste burial grounds or other means. The following 16 radionuclides were selected for this modeling effort: carbon-14 (C-14), chlorine-36 (Cl-36), tritium (H-3), iodine-129 (I-129), neptunium-237 (Np-237), rhenium-187 (Re-187), strontium-90 (Sr-90), technetium-99 (Tc-99), uranium-232 (U-232), uranium-233 (U-233), uranium-234 (U-234), uranium-235 (U-235), uranium-236 (U-236), uranium-238 (U-238), radium-226 (Ra-226), and thorium-230 (Th-230). The simulation time starts in 1943 and ends at 12070, which is 10,000 years after assumed Hanford Site closure in 2070. The parallel version of the Subsurface Transport Over Multiple Phases (STOMP 1 ) simulator, officially named the exascale Subsurface Transport Over Multiple Phases (eSTOMP), is used to simulate flow and transport for the vadose models. The documentation for the STOMP code is comprehensive. The theoretical and numerical approaches applied in the STOMP code are documented in a published theory guide (PNNL-12030, STOMP Subsurface Transport Over Multiple Phases Version 2.0 Theory Guide). The code has undergone a rigorous verification procedure against analytical solutions, laboratory-scale experiments, and field-scale demonstrations. The application guide (PNNL-11216, STOMP Subsurface Transport Over Multiple Phases Application Guide) provides instructive examples in the application of the code to classical groundwater problems. The user’s guide (PNNL-15782, STOMP: Subsurface Transport Over Multiple Phases Version 4.0: User’s Guide) describes the general use, input file formatting, compilation, and execution of the code. The primary output of the vadose zone modeling is radionuclide transfer rates to the groundwater for input into the saturated zone model. The rates will be summed over the 100 by 100 m saturated zone model grid cells that fall within the vadose zone model source domain.
The objectives of the vadose modeling for the updated Hanford Site composite analysis (CA) are to simulate the flow and transport of water and radionuclide releases from the surface to the water table and to provide radionuclide transfer rates for the plateau to river (P2R) model, version 8.3 (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). Water additions include natural recharge and water discharged to the ground as a result of industrial processes associated with Hanford Site operations. Contaminant sources include radionuclides in water discharged to the ground during operations and radionuclides disposed “dry” in solid waste burial grounds or other means. The following 16 radionuclides were selected for this modeling effort; carbon-14 (C-14), chlorine-36 (Cl-36), tritium (H-3), iodine-129 (I-129), neptunium-237 (Np-237), rhenium-187 (Re-187), strontium-90 (Sr-90), technetium-99 (Tc-99), uranium-232 (U-232), uranium-233 (U-233), uranium-234 (U-234), uranium-235 (U-235), uranium-236 (U-236), uranium-238 (U-238), radium-226 (Ra-226), and thorium-230 (Th-230). The simulation time starts in 1943 and ends at 12070, which is 10,000 years after assumed Hanford Site closure in 2070.
With this project, we aim to further enhance our understanding of fundamental f-element chemistry, including electronic structure and bonding behaviors. Key project goals include the characterization of actinide complexes bearing redox-active ligands, including those of lower-oxidation state uranium, and examining how structural changes to the ligand and coordination sphere affect structure and bonding. Redox-active and redox non-innocent ligands have been used widely in transition metal chemistry, but uranium complexes with redox-active ligands are surprisingly rare. We recently reported the synthesis of the redox-active ligand, “phen-BIAN” (N,N’-bis(iminophenol)acenaphthene), in an investigation of the electronic behavior of uranium and other actinides. This ligand framework borrows features from two classes of Schiff base ligands—the tetradentate O-N-N-O binding pocket from salens, and the redox-active α-diimine unit and backbone from Ar-BIANs (N,N’-bis[(aryl)imino]acenaphthenes, which can accept up to four electrons upon reduction. To continue this work, the electronics of uranyl and thorium complexes will be probed using the reduced forms of these ligands, using these in the preparation of lower-oxidation state and non-oxo uranium complexes. Additional members of the phen-BIAN family will be synthesized, including naphthol and thiol derivative. With these we can characterize the influence of substitutent groups on the redox activity, coordination geometry, and covalent interactions. The work proposed here entails extensive preparation, structural and spectroscopic characterization, of an array of actinide complexes. This will allow us to address probative questions about the nature of actinide bonding, the degree of covalency, the validity of lanthanides as models for the actinides, hard-soft interactions, magnetic interactions between metals in bimetallic complexes and what combination of electronic and steric affects produce an actinide selective ligand. The latter will assist greatly in providing a benchmark against which to compare and evaluate the distinct behaviors exhibited by 5f-element complexes. This will enable us to learn about the differences in binding between the 4f lanthanides and the 5f elements like uranium and plutonium. Such difference in binding can be exploited in separations and the development of new materials.
The objectives of the vadose modeling for the updated Hanford Site composite analysis (CA) are to simulate the flow and transport of water and radionuclide releases from the surface to the water table and to provide radionuclide transfer rates for the plateau to river (P2R) model, version 8.3 (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). Water additions include natural recharge and water discharged to the ground as a result of industrial processes associated with Hanford Site operations. Contaminant sources include radionuclides in water discharged to the ground during operations and radionuclides disposed “dry” in solid waste burial grounds or other means. The following 16 radionuclides were selected for this modeling effort: carbon-14 (C-14), chlorine-36 (Cl-36), tritium (H-3), iodine-129 (I-129), neptunium-237 (Np-237), rhenium-187 (Re-187), strontium-90 (Sr-90), technetium-99 (Tc-99), uranium-232 (U-232), uranium-233 (U-233), uranium-234 (U-234), uranium-235 (U-235), uranium-236 (U-236), uranium-238 (U-238), radium-226 (Ra-226), and thorium-230 (Th-230). The simulation time starts in 1943 and ends at 12070, which is 10,000 years after assumed Hanford Site closure in 2070.
The objectives of the vadose modeling for the updated Hanford Site composite analysis (CA) are to simulate the flow and transport of water and radionuclide releases from the surface to the water table and to provide radionuclide transfer rates for the plateau to river (P2R) model, version 8.3 (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). Water additions include natural recharge and water discharged to the ground as a results of industrial processes associated with Hanford Site operations. Contaminant sources include radionuclides in water discharged to the ground during operations and radionuclides disposed "dry" in solid waste burial grounds or other means. The following 16 radionuclides were selected for this modeling effort: carbon-14 (C-14), chlorine-36 (Cl-36), tritium (H-3), iodine-129 (I-129), neptunium-237 (Np-237), rhenium-187 (Re-187), strontium-90 (Sr-90), technetium-99 (tc-99), uranium-232 (U-232), uranium-233 (U-233), uranium-234 (U-234), uranium-235 (U-235), uranium-236 (U-236), uranium-238 (U-238), radium-226 (Ra-226), and thorium-230 (Th-230). The simulation time starts in 1943 and ends at 12070, which is 10,000 years after assumed Hanford Site closure in 2070.
A critical barrier to the deployment of MSRs is the absence of a well-defined nuclear material control and accounting (MC&A) approach, a vital prerequisite to meet NRC licensing requirements as well as facilitating future international exports. Liquid-fueled MSR variants (especially those incorporating online refueling or reprocessing) present a unique set of challenges to traditional nuclear material control and accountancy. Unlike solid-fueled light-water reactors, traditional item-counting methods cannot be applied as an accountancy strategy. Rather, MC&A approaches to MSR variants (including both uranium and thorium fueled designs) are more analogous to bulk material handling facilities (e.g., enrichment and reprocessing); yet further complicating matters is the fact that fuel medium is also highly radioactive. Meanwhile, the space of MSRs covers a broad range of design parameters, including thermal and fast spectra designs; operation in actinide breeder or burner modes, choice of actinide fuel used (e.g., 235 U, 232 Th / 233 U, denatured 233 U, etc.), pool or loop-type configuration, and even different salt chemistry. Each of these design choices introduce significant challenges to MC&A approaches within MSR facilities. We propose to bridge this gap for liquid-fueled MSRs by developing a modular, component-based test framework for evaluating viable process monitoring and MC&A techniques specifically suited to liquid-fueled MSR system variants employing online refueling or reprocessing. This test platform will consist of a toolbox of independent process modules representing discrete physical units (such as the reactor core, off-gas processing, decay tanks, and actinide separation units), each with its own self-contained physics responsive to the input mass flow, along with appropriate measurement models that can be coupled to key flow points. These dynamic physical signatures thus afford the ability to test the viability and efficacy of potential accountancy techniques under the full range of reactor operating conditions. As process modules are connected via mass flows, the result is a reconfigurable, generic MSR mass flow model capable of serving as an MC&A test platform for a broad spectrum of possible MSR configurations. The resulting MSR MC&A toolbox will enable robust assessment of accountancy strategies for this unique facility type, including analysis of physical feedbacks arising both from depletion of the fuel over time as well as from potential off-normal events, including those introduced by equipment failures (e.g., a pump failure) as well as by malicious action (i.e., attempts to divert material). The proposed toolbox both addresses a critical needs area for the MPACT analysis toolkit while leveraging existing MPACT-sponsored tools, especially with respect to simulation of measurement and accountancy techniques for advanced fuel cycle facilities. Beyond enabling new analysis capabilities for MSR systems, the design of this toolbox will be to such to maximize compatibility with existing MPACT tools, such to enhance existing facility MC&A analysis capabilities.
Lawrence Livermore National Security (LLNS) and the U.S. Department of Energy (DOE) are in the process of returning the area where Building 175 existed to beneficial use for future site development. The completed assessment will help LLNS and DOE to outline project scope and costs associated with the removal, characterization, and disposal of materials generated when the concrete slab for the former building and any associated remaining subsurface structures are demolished. Slab removal under the Transition & Disposition process requires full screening for potential site contamination to determine appropriate future land use. Borehole locations and depths were designed to correctly assess DOE’s future liability for characterizing residual vadose zone contamination. If a residual source area is identified at depth, DOE will need to evaluate the additional cost of future subsurface cleanup (with limited access) due to planned development. This is necessary to leave the location in a “ready-to-build” status. As a result, Phase II sampling requirements may in some cases extend beyond the construction zone required for slab removal to ensure the necessary due diligence. To avoid the potential spread of contamination and/or the creation of an environmental release by impacting the integrity of known contamination areas (e.g., pit within room 102 and the east to west boundary seam), these locations were not sampled for this project. During demolition of the slab, these locations and their underlying soils should be further evaluated. The assessment was conducted in accord with the May 2022 Lawrence Livermore National Laboratory Former Building 175 Assessment Soil Sampling and Analysis Plan / Quality Assurance Plan. Thirty-six, direct-push borings were advanced, along with collecting concrete (where present) and soil samples for laboratory analyses. Thirty-two of the borings were advanced to a depth of 25 feet below ground (bgs), and four borings were advanced to a depth of 55 feet bgs. The concrete slab for former Building 175 ranged from approximately 8 inches to over two feet in thickness. Soils encountered during the investigation consisted primarily of clayey silt, with interbeds of sandy gravel and silty sand to the total depth explored of 55 feet bgs. Field photoionization detector readings – checking for volatile organic compound (VOC) vapors in soils, ranged from zero (0) to a peak of 33 parts per million at 25 feet bgs in boring PC-B175- 028. The cause for the peak reading is unknown, however, no visually discolored or odorous soils were encountered during the assessment and all VOC results were below Lawrence Livermore National Laboratory’s (LLNL’s) Soil Screening and Management Plan (SSMP) soil screening levels (SSL). Groundwater was not encountered during the assessment and is expected to occur at roughly 65 feet bgs in the project area. No metals were detected at concentrations of concern in the concrete core samples collected and analyzed. Low gross alpha and beta activity concentrations were detected in the concrete core samples collected and analyzed. The detected activity concentrations would appear to be from naturally occurring radioactive isotopes, i.e., potassium 40, present in the raw materials used to make concrete and not artificially added. Tritium was not detected above the testing laboratory's Method Detection Limit (MDL) in any of the concrete core samples collected and analyzed. The radioactive isotopes - actinium 228, bismuth 214, lead 212, lead 214, potassium 40, radium 226, radium 228, and thallium 208, were detected at low activity concentrations in the concrete core samples analyzed. Based on the detected activity concentrations, the isotopes would appear to be naturally occurring in the raw materials used to make concrete and not artificially added. Acetone – a common laboratory contaminant, was detected in nine of the soil samples collected and analyzed. Concentrations of two other volatile organic compounds (benzene and tetrachloroethene) were detected in five of the soil samples analyzed. All concentrations were below SSLs. Total petroleum hydrocarbons as diesel range organics were detected at 43.9 milligrams per kilogram (mg/kg) in the 20-foot bgs duplicate sample from boring PC-B175-007. Total petroleum hydrocarbons as motor oil were detected at 7.20 mg/kg in the 15-foot bgs routine sample from boring PC-B175-001, and at 20.7 mg/kg in the 20-foot bgs duplicate sample from boring PC-B175-007. The SSL for diesel-range TPHs is 260 mg/kg. LLNL does not have an SSL for motor oil range TPHs. No indications of a release, e.g., visibly stained, or odorous soil, were present at the boring locations. No samples collected contained polychlorinated biphenyls (PCBs) in concentrations above the laboratory reporting limit. Arsenic was detected above its SSL of 8.51 mg/kg in the 25-foot bgs routine sample collected from boring PC-B175-023. Nickel was detected above its SSL of 86.0 mg/kg in the 10-foot bgs routine sample from boing PC-B175-005, the 20-foot bgs routine sample from boring PC-B175-025, and the 25-foot bgs routine sample from boring PC-B175-034. The detected concentrations, however, were well below ten times (10x) their respective STLCs. Gross alpha and/or gross beta were detected above their respective SSL activity concentrations in three routine soil samples. Retesting (two per sample) of the samples showed that the initial reported activity concentrations were anomalous. Tritium was not detected in any of the routine or duplicate soil samples collected and analyzed during the investigation. The radioactive isotopes - actinium 228, bismuth 212 and 214, lead 212 and 214, potassium 40, radium 224, 226 and 228, thallium 208, thorium 234 and uranium, were detected at low activity concentrations in the soil samples analyzed for radioactive constituents. The detected isotopes and their associated activity concentrations are typical of those naturally occurring in the marine-type sedimentary deposits underlying the Livermore Valley. No radiological controls are necessary for the soil evaluated.
The objectives of the vadose modeling for the updated Hanford Site composite analysis (CA) are to simulate the flow and transport of water and radionuclide releases from the surface to the water table and to provide radionuclide transfer rates for the plateau to river (P2R) model, version 8.3 (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). Water additions include natural recharge and water discharged to the ground as a result of industrial processes associated with Hanford Site operations. Contaminant sources include radionuclides in water discharged to the ground during operations and radionuclides disposed “dry” in solid waste burial grounds or other means. The following 16 radionuclides were selected for this modeling effort; carbon-14 (C-14), chlorine-36 (Cl-36), tritium (H-3), iodine-129 (I-129), neptunium-237 (Np-237), rhenium-187 (Re-187), strontium-90 (Sr-90), technetium-99 (Tc-99), uranium-232 (U-232), uranium-233 (U-233), uranium-234 (U-234), uranium-235 (U-235), uranium-236 (U-236), uranium-238 (U-238), radium-226 (Ra-226), and thorium-230 (Th-230). The simulation time starts in 1943 and ends at 12070, which is 10,000 years after assumed Hanford Site closure in 2070.
Molten Salt Reactors (MSRs) are one of six Generation IV reactor designs currently under development around the world. Because of the unique operating conditions of MSRs, which include molten fuel and the continuous removal of gaseous fission products during operation, work was performed to analyze the potential impact of emissions on the International Monitoring System (IMS) of the Comprehensive Nuclear-Test-Ban Treaty (CTBT). Simulations were performed to predict the production of IMS-relevant radionuclides in four MSR designs operating under two scenarios – (1) a sealed reactor with releases only during operational shutdown and (2) continuous reprocessing or sparging of the fuel salt. From these production estimates the radioxenon and radioiodine signatures were extracted and compared to three current reactor designs (PWR, BWR, RBMK). In the cases where continuous reprocessing of the fuel salt occurred both the radioxenon and radioiodine signatures are nearly indistinguishable from a nuclear explosion. Estimates were also made of the potential emission rate of radioxenon for three reactor designs and it was found that MSRs have the potential to emit radioxenon isotopes at a rate of 1015 – 8×1016 Bq/d for 133Xe if no abatement is used. An assessment was also made of activation products using a candidate fuel salt (FLiBe) mixed with corrosion products for the Thorium Molten Salt Reactor (TMSR-LF1)
The material was prepared as part of an independent review (Schubert Review) for the Thorium Fuel Safeguards project.
A vacuum induction melting (VIM) furnace was used to produce an ~120 kg depleted uranium (DU) rod in November 2021 from well characterized feedstock to investigate the separation of thorium (Th) and protactinium (Pa) from uranium (U) during U metal casting and quantify the behavior of the 230 Th/ 234 U and 231 Pa/ 235 U radiochronometry systems. This work suggested that while 234 Th, measured by gamma spectrometry, appears to segregate to the top and surface of the rod, the concentration of 230 Th determined by isotope dilution mass spectrometry (IDMS) in drill turnings from multiple locations in the rod, including the hot top, is relatively consistent. To evaluate whether Th is potentially enriched at only the very outer surface of the cast DU rod relative to the bulk material in the cast rod, thin surface samples were collected from the cast DU rod. Locations sampled included the inner diameter (ID) and outer diameter (OD) of the bottom of the casting and the ID, OD, and top face of the hot top (very top of the casting). The locations are shown in Figure 1. Four samples were taken from each location at different depths in the cast material. Each cut took approximately 0.03 – 0.05” off of the casting.
The sodium-cooled fast reactor (SFR) design concept is one of the six classes of nuclear reactors in the GenIV initiative. SFRs are uranium or plutonium-fueled reactors operating in the fast neutron spectrum using liquid sodium as the coolant. SFRs can be designed as a breeder reactor or actinide-burning reactor in addition to operating the thorium fuel cycle. While having different fuel designs, the anticipated waste streams, and the necessary management strategies for spent nuclear fuel (SNF) and radioactive wastes from SFRs are very similar. This includes the SNF, activated sodium coolant, in-core stainless-steel components, piping, resins and filters, solidified liquid waste, contaminated equipment, and other radioactive wastes. Modern SFR designs are based on a long and rich operating history of several liquid-metal-cooled fast reactors with sodium coolant. Several of these reactors have been shut down, the fuel has been placed in safe storage, and they have undergone some degree of decommissioning. As such, there is significant experience in the management of the SNF and radioactive wastes associated with operating these reactors. This white paper will identify the definitions and regulations that apply to the safe and secure management, storage, and disposal of radioactive waste and identify the key radioactive waste streams from SFRs. Idaho National Laboratory has significant experience in the management of the SNF from the SFR predecessors. This experience should form the basis for the management and disposition efforts of the radioactive waste from any new SFR-type small modular reactor or microreactor intended for deployment at the Idaho National Laboratory Site
This report details an assessment of the hazards and safety impacts related to front-end operations of molten salt reactors (MSR) as well as an assessment of existing safety guidance. Publicly available information was evaluated to make recommendations to the U.S. Nuclear Regulatory Commission (NRC) for guidance development and information gathering needs. Five different MSR technologies were evaluated along with information from 1960’s about the Atomic Energy Commission programs for the Aircraft Reactor Experiment and Molten Salt Reactor Experiment. Primary areas of evaluation include fuel cycle facilities, transportation and at reactor fuel mixing operations up to reactor startup. In general, there was difficulty synthesizing publicly available information due to the early stage of the MSR development and proprietary information associated with the reactor technology companies analyzed. There are a few specific recommendations from this report. One overarching paradigm shift that the NRC needs to evaluate is the possibility of collocating fuel cycle facilities with operating MSRs. Although there is no specific prohibition to this in the NRC regulations, the collocation of the fuel cycle facilities with the operating MSR presents a novel approach compared to the light water reactor baseline. More guidance and research into thorium operations and regulation is needed. The hazards associated with the stability of stored fuel constituents need to be evaluated. Some reactor fuel cycles use beryllium, and its use and the associated hazards need further analysis. NRC-approved designs for transportation packages for shipping molten salt fuels and factory-built and fueled reactors are not available.
This paper will document the air emissions source term for the TA-53 Building 0984 Isotope Production Facility (IPF). The facility has historically been managed as a minor source under Radionuclide NESHAP regulations, but began using a wider variety of irradiation targets and a higher beam current. To support expanded generation of actinium-225 for medical diagnostic and therapeutic uses, IPF is now irradiating thorium targets and the beam current is planned to increase from 250 microamperes up to 600 microamperes. These changes merit a review of the anticipated source term under the new proposed operational conditions. The end result of the review indicates the main stack (Exhaust Stack ES-1) needs to be managed as a major source with continuous emissions monitoring. No additional advance notifications or permitting is required as a result of these operational changes.