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Toward Rapid Actinium-225 Purification via Membrane Adsorbers with Covalently Tethered Diglycolamide Ligands
Extractive diglycolamide (DGA) resins are used in several state-of-the-art techniques for purifying 225 Ac, a promising radiometal for targeted alpha therapy. Unfortunately, separation processes that rely on resins are often limited to slow flow rates, high elution volumes, and long processing times. Membrane adsorbers functionalized with DGA ligands are an alternative separation material that may overcome these challenges. This work presents (1) the synthesis of an aminated tetrahexyldiglycolamide ligand, (2) the covalent tethering of the ligand to electrospun poly(vinylbenzyl chloride) fiber mats, and (3) the adsorption and desorption of La(III) and 225 Ac. Chemical and physical characterization supports the covalent tethering of the ligand to the fiber mat, as well as the preservation of the fiber surface area and porosity after functionalization. Equilibrium adsorption experiments were performed with stable La(III) and radioactive 225 Ac. Trends in affinity are consistent between commercial resins and the synthesized membrane adsorbers; however, the Langmuir constants and the maximum binding capacity of the membrane adsorbers were generally lower than the resins. Despite these differences, the modeled selectivity for an equimolar solution of La(III)/ 225 Ac in 10 M nitric acid is 57. Furthermore, 225 Ac is rapidly desorbed from the fibers in 10 M nitric acid (<20 min). The La(III)/ 225 Ac selectivity and rapid 225 Ac desorption indicate this class of materials is promising for rapid radioanalytical separations.
Precision Atomistic Structures of Actinium-/Radium-/Barium-Doped Lanthanide Nanoconstructs for Radiotherapeutic Applications
Not Available
Synthesis and Stability of Actinium-225 Endohedral Fullerenes, 225 Ac@C 60
Not Available
Development of an actinium-225 radioimmunoconjugate for targeted alpha therapy against SARS-CoV-2
Cytotoxicity was induced in cells mimicking SARS-CoV-2 infection by a 225 Ac-radiolabeled antibody that targets the RBD2 of the spike protein.
Developing Inorganic Resins for Radium and Actinium Generators and Purifications
The inorganic, normal-phase sorbents alumina, titania, and zirconia were evaluated and screened for the separation of Ba, La, 228 Ra, 228 Ac, and 212 Pb in a dilute acid matrix. The results show that the sorbents are capable of fractionating the ions between pH 1–8. Acetate and total metal ion concentrations were experimentally evaluated as factors that could affect retention using La and Ba surrogates. Pseudo-second order rate constants were derived and the uptake of La was determined to be endothermic. A stationary zirconia column was used to isolate Ba from La and Ra from Ac/Pb; elution profiles of each separation are presented. The utility and implications of these sorbents are discussed with respects to large-scale production of 225 Ac from radium targets. This work was published in 2020 and in 2022.
Purification of actinium-225 from thorium via selective precipitation
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Separation of zirconium and hafnium from early actinides and rare earth elements with eichrom’s pb resin in HCl
The separation of zirconium and hafnium isotopes from the early actinides and rare earth elements (REE) with Eichrom’s Pb resin has been studied. Batch studies were performed to characterize the behavior of actinium, thorium, zirconium, hafnium, lutetium, and yttrium on Pb resin from HCl solutions (0.001 M to 11 M). The early actinides and REE had no affinity for the resin at any concentration of HCl, but zirconium and hafnium showed a moderate uptake at high concentrations of HCl with a maximum extraction at 11 M HCl. Several column separations were tested, including with only tracer isotopes and with mass. Rapid, simple separations of zirconium from actinium, thorium, protactinium, and the REE with high yields and low elution volumes are presented with applications for tracer isotope production and fission product separations. Furthermore, the resin is less suitable for hafnium separations as hafnium tends to bleed off the resin even at high concentrations of HCl.
Data Summary Report for Soil and Slab Sampling at Former Building 175
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.
Development of 225Ac-doped biocompatible nanoparticles for targeted alpha therapy
Abstract Targeted alpha therapy (TAT) relies on chemical affinity or active targeting using radioimmunoconjugates as strategies to deliver α-emitting radionuclides to cancerous tissue. These strategies can be affected by transmetalation of the parent radionuclide by competing ions in vivo and the bond-breaking recoil energy of decay daughters. The retention of α-emitting radionuclides and the dose delivered to cancer cells are influenced by these processes. Encapsulating α-emitting radionuclides within nanoparticles can help overcome many of these challenges. Poly(lactic- co -glycolic acid) (PLGA) nanoparticles are a biodegradable and biocompatible delivery platform that has been used for drug delivery. In this study, PLGA nanoparticles are utilized for encapsulation and retention of actinium-225 ([ 225 Ac]Ac 3+ ). Encapsulation of [ 225 Ac]Ac 3+ within PLGA nanoparticles (Z ave = 155.3 nm) was achieved by adapting a double-emulsion solvent evaporation method. The encapsulation efficiency was affected by both the solvent conditions and the chelation of [ 225 Ac]Ac 3+ . Chelation of [ 225 Ac]Ac 3+ to a lipophilic 2,9-bis-lactam-1,10-phenanthroline ligand ([ 225 Ac]AcBLPhen) significantly decreased its release (< 2%) and that of its decay daughters (< 50%) from PLGA nanoparticles. PLGA nanoparticles encapsulating [ 225 Ac]AcBLPhen significantly increased the delivery of [ 225 Ac]Ac 3+ to murine (E0771) and human (MCF-7 and MDA-MB-231) breast cancer cells with a concomitant increase in cell death over free [ 225 Ac]Ac 3+ in solution. These results demonstrate that PLGA nanoparticles have potential as radionuclide delivery platforms for TAT to advance precision radiotherapy for cancer. In addition, this technology offers an alternative use for ligands with poor aqueous solubility, low stability, or low affinity, allowing them to be repurposed for TAT by encapsulation within PLGA nanoparticles. Graphical Abstract
Examination of Ac-225 production from Ra-226 using fast reactor JOYO
In this study, the authors investigated the method of producing the radionuclide Ac{sup 225} used for targeted alpha therapy (TAT). Currently, Ac{sup 225} is mainly generated from ORNL's Th{sup 229} generator, and the annual production amount is limited to about 63 GBq, and methods for generating it using accelerators are under development in each country. The method using an accelerator has the advantage of being able to generate Ac{sup 225} from a small amount of target nuclides with high efficiency but has the disadvantage of not being able to irradiate a large amount of target nuclides at once due to the small irradiation area. Therefore, the authors investigated a method to generate Ac{sup 225} by neutron irradiation of Ra{sup 226} as a target nuclide using the experimental fast reactor JOYO, which has abundant neutrons and a large loading region. Irradiation of Ra{sup 226} with fast neutrons causes a (n, 2n) reaction to generate Ra{sup 225}, and then decay to produce Ac{sup 225}. In addition, although harmful Ac{sup 227} is also produced at the same time by the (n,γ) reaction, first of all the actinium isotope is chemically separated and eliminated. Since the remaining Ra{sup 225} collapses and Ac{sup 225} is produced, pure Ac{sup 225} can be extracted by performing chemical separation again. As a result of the analysis, 1 g of Ra{sup 226} is irradiated with JOYO for 60 days, and milking is performed 4 times every 17.5 days. By doing these three times a year, it was found that about 50 GBq of Ac{sup 225} was generated. (authors)
Polyoxometalates as ligands to synthesize, isolate and characterize compounds of rare isotopes on the microgram scale
The synthesis and study of radioactive compounds are both inherently limited by their toxicity, cost and isotope scarcity. Traditional methods using small inorganic or organic complexes typically require milligrams of sample—per attempt—which for some isotopes is equivalent to the world’s annual supply. Here we demonstrate that polyoxometalates (POMs) enable the facile formation, crystallization, handling and detailed characterization of metal–ligand complexes from microgram quantities owing to their high molecular weight and controllable solubility properties. Three curium–POM complexes were prepared, using just 1–10 μg per synthesis of the rare isotope 248 Cm 3+ , and characterized by single-crystal X-ray diffraction, showing an eight-coordinated Cm 3+ centre. Moreover, spectrophotometric, fluorescence, NMR and Raman analyses of several f-block element–POM complexes, including 243 Am 3+ and 248 Cm 3+ , showed otherwise unnoticeable differences between their solution versus solid-state chemistry, and actinide versus lanthanide behaviour. Furthermore, this POM-driven strategy represents a viable path to isolate even rarer complexes, notably with actinium or transcalifornium elements.
Direct identification of Ac and No molecules with an atom-at-a-time technique
The periodic table provides an intuitive framework for understanding chemical properties. However, its traditional patterns may break down for the heaviest elements occupying the bottom of the chart. Here, the large nuclei of actinides (Z > 88) and superheavy elements (Z ≥ 104) give rise to relativistic effects that are expected to substantially alter their chemical behaviours, potentially indicating that we have reached the end of a predictive periodic table. Relativistic effects have already been cited for the unusual chemistry of the actinides compared with those of their lanthanide counterparts. Unfortunately, it is difficult to understand the full impact of relativistic effects, as research on the later actinides and superheavy elements is scarce. Beyond fermium (Z = 100), elements need to be produced and studied one atom at a time, using accelerated ion beams and state-of-the-art experimental approaches. So far, no experiments have been capable of directly identifying produced molecular species. Here ions of actinium (Ac, Z = 89) and nobelium (No, Z = 102) were synthesized through nuclear reactions at the 88-Inch Cyclotron facility at Lawrence Berkeley National Laboratory and then exposed to trace amounts of H 2 O and N 2 . The produced molecular species were directly identified by measuring their mass-to-charge ratios using FIONA (For the Identification Of Nuclide A). These results mark the first, to our knowledge, direct identification of heavy-element molecular species using an atom-at-a-time technique and highlight the importance of such identifications in future superheavy-element chemistry experiments to deepen understanding of their chemical properties.
Expanding on the ability of trivalent actinides to support microbial alcohol metabolism in evolved methylotrophic bacterium
The 4 f elements, known as the lanthanides, have only recently been recognized as biologically essential metals. These elements can be found in the active site of certain alcohol dehydrogenase (ADH) enzymes, which are used by methylotrophic bacteria to metabolize simple alcohols such as methanol and ethanol. The 5 f elements, known as the actinides, often show similar chemical behaviour to the lanthanides and recent reports demonstrated that americium (Am) and curium (Cm) can replace lanthanides in certain ADHs to yield a catalytically competent enzyme and support bacterial life. In this work, we expand on these results to show the trivalent ions actinium (Ac3+), americium (Am3+), curium (Cm3+), berkelium (Bk3+), and californium (Cf3+) all support growth of an evolved strain of the model methylotroph Methylobacterium extorquens AM1. Further in vitro experiments using a reconstituted ethanol dehydrogenase enzyme confirm the ability of this enzyme to utilize trivalent actinide ions.
Measurement of the 230 Th( p ,2n)Pa229 and 230 Th( p ,3n)Pa228 reaction cross sections from 14.1 to 16.9 MeV
Actinium-225 is of interest for medical isotope production and there is on-going research into methods of producing Ac 225 , either directly or via the decay of its parent isotopes ( Th 229 , Pa 229 , and Ra 225 ). One method that has been suggested is the Th 230 ( p , 2 n ) Pa 229 reaction. However, there is no available cross-section data for this reaction in the literature. Purpose: Measure the Th 230 ( p , 2 n ) and Th 230 ( p , 3 n ) reaction cross sections in the energy range where the ( p , 2 n ) reaction is predicted to peak to determine the feasibility of Ac 225 production via the Th 230 ( p , 2 n ) reaction. Methods: Targets naturally enriched in Th 230 were irradiated at the Center for Accelerator Mass Spectrometry at Lawrence Livermore National Laboratory with energies ranging from 14.1 to 16.9 MeV. Furthermore, chemical processing was used to separate the protactinium activation products, followed by γ -ray spectroscopy to measure the activities of Pa 228 , 229 , 230 , 232 produced in the irradiation. Results: We find that excitation functions are reported for the first time in the literature for the Th 230 ( p , 2 n ) and Th 230 ( p , 3 n ) reactions in this energy range. The peak measured value of the Th 230 ( p , 2 n ) reaction was found to be 182 ± 12 mb at 14.4 ± 0.1 MeV. The Th 232 ( p , n ) Pa 232 reaction was used to verify the experimental conditions, the measured values are reported and are comparable to the existing literature values. From the γ -ray spectrometry data, the half-life of Pa 229 was measured as 1.5 ± 0.1 days, which is within the error of the half-life reported in the evaluated nuclear data as well as in the recent measurements, and the half-life of Pa 228 was measured as 19.5 ± 0.4 hours. Conclusions: Overall, the Th 230 ( p , 2 n ) Pa 229 reaction could reasonably be used for Ac 225 isotope production, although significant amounts of relatively isotopically pure Th 230 would be needed for significant production because the low alpha-decay branching ratio of Pa 229 and long half-life of Th 229 inhibit the in-growth of significant amounts of Ac 225 .
225 Ac/ 213 Bi Generator Based on Millifluidics Controlled Electrodeposition
Radioisotopes provide both diagnostic tools and therapeutic treatments for cancer and other diseases. In the US, millions of radioisotope doses are given to patients per year. Radiopharmaceutical generators are widely used to provide such short-lived medical radioisotopes in a clinical setting. These generators work by exploiting chemical differences in a parent/daughter isotope relationship. Actinium-225 (half-life 10 d) is used to provide clinically useful amounts of daughter isotopes 213 Bi (46 m). An integrated millifluidic 225 Ac/ 213 Bi radiopharmaceutical generator device was engineered to produce 213 Bi labeled biomolecules. Using recent LANL successes in additive manufacturing of small-scale fluidic devices, a disposable device was developed that integrates three steps for the production of 213 Bi labeled antibodies: 1) 213 Bi separation from 225 Ac parent, 2) 213 Bi antibody labeling, and 3) purification of the labelled antibody.
The Uranium-Containing and Thorium-Containing Anions Studied by Photoelectron Spectroscopy
An in-depth knowledge of actinide chemistry is fundamental to many aspects of nuclear science and technology, including the synthesis and processing of materials and the remediation of waste disposal sites. Among the actinides, the chemical bonding behaviors of actinium and thorium resemble those of the transition metals; the 5f-electrons of protactinium, uranium, neptunium, and plutonium often play important roles in their bonding; and among the still heavier elements, their bonding tends to mimic the lanthanide elements in terms of electron shielding and their f-electron contributions. Bonding that involves 5f-electrons, however, is especially important, in part because of the significance of uranium and plutonium, but also because these elements are among the few where f-electron participation in bonding is relatively common. This work focused on studying uranium-containing and thorium-containing anions in the gas phase using negative ion photoelectron spectroscopy. Since this technique directly probed valence electrons, it was uniquely positioned to address open questions regarding molecular bonding and electron configurations. A particularly important issue concerned how bonding in actinide-containing molecules was affected by modifications to their actinide atoms’ environment, i.e., due to their interaction with ligands. A closely related question was how actinide atoms’ suborbitals were qualitatively reordered and their energies quantitatively shifted as a result of their ligated environments. These were especially relevant issues in regard to uranium due to it having multiple possible oxidation states (OS) and the potential for 5f electron participation in bonding. The effects of ligands on oxidation states and 5f-orbital energies in uranium bonding was expected to be pronounced. Both ligands and excess electrons were seen as probes of actinide atoms within actinide-containing molecules. Our strategy for advancing knowledge of chemical bonding in the actinide-containing species utilized the synergy between experiments and theory, where in some cases experimental results validated theory and where in others computational results assisted in interpreting experiments. Calculations on actinide systems are terrifically challenging due to large spin-orbit interactions, relativistic effects, and just the sheer number of electrons involved. Even in the simplest species, e.g., U and U2, the most sophisticated, modern calculations carried out by the most experienced theorists often only approximate experimentally-measured values, such as electron affinities. For theory to provide confident predictions that can be used to solve real problems it needed an iterative and ultimately corrective mechanism by which its methods can develop further. Experiments can be used to identify when theory has failed; whereupon the subsequent process of using the experiment-theory interplay can be used to find the cause of the failure. Upon fixing it in one case, different test species can be proposed and studied by the experiment-theory combination to determine whether the problem has been corrected. Thus, experiments not only measure the values of molecular properties, they also provide navigational 3 beacons that keep computations off the reefs in an otherwise dark sea with few reference points. Experimental measurements in the actinide field are not only important, they are in actuality essential to computational progress. While it was not always possible to compare the theoreticallydetermined quantity of interest directly with the same experimentally-measured observable, it was usually possible to compare consequential properties that are both calculable and measurable. In the work completed here electron affinities and electronic state spacings were often sensitive consequential parameters. Reasonable agreement between measured and computational values signaled that a calculation that was very likely to be on-track. We had established collaborative relationships with five computational groups, all of which have expertise in computational actinide chemistry. Their PI’s are L. Cheng, D. Dixon, L. Gagliardi, K. Peterson, and B. Vlaisavljevich. Our close interaction with our theory partners led to us suggesting systems to them and them to us. This reciprocal interaction between our experimental and their computational results was among the most important strengths of this work and was a thread woven throughout. Even though anion photoelectron spectroscopic studies are conducted on anions, much of the information that they provide, pertains to the electronic structure of the neutral counterparts of those anions; among these are electron affinities and electronically excited state spacings. Our experimental tools included several specialized ion sources for forming the anionic species of interest, a mass spectrometer for identifying and mass-selecting them, and an anion photoelectron spectrometer for determining their electron affinities (EA) and characterizing the electronic states of the selected anions’ neutral counterparts. Anion photoelectron spectroscopy is conducted by crossing a mass-selected beam of anions with a fixed-frequency laser beam and energy-analyzing the resultant photodetached electrons. The photodetachment process is governed by the energyconserving relationship: hν = EBE + EKE, where hν is the photon’s energy, EBE is the electron binding (photodetachment transition) energy, and EKE is the electron’s kinetic energy. In our apparatus mass-selection is accomplished via time-of-flight mass spectrometry (TOF-MS), electron energy analysis is achieved with either a magnetic bottle or by velocity mapped imaging. Photodetachment of electrons from anions is implemented via either Nd:YAG or excimer lasers. The photodetachment transition energy, i.e., the EBE, between the ground vibrational and electronic state of an anion and the ground vibrational and electronic state of that anion’s neutral counterpart is the adiabatic electron affinity (EA) of that neutral molecule. Likewise, photodetachment transitions between the ground vibrational and electronic state of an anion and the various electronically-excited states of that anion’s corresponding neutral map the electronic spectrum of that neutral species, i.e., the spectral spacings in the photoelectron spectrum are a mirror image of the neutral’s electronic spectrum. It was, of course, crucial to be able to form the anionic species of interest. There, we had a particularly broad field of anion sources from which to choose. These included several variants of pulsed laser vaporization (LV), laser photoemission, infrared desorption plus photoemission, pulsed arc discharge (PACIS), electrospray ionization (ESI), and Rydberg electron transfer (RET). Each of these anion sources were readily combined with, i.e., connected to, the anion photoelectron spectroscopic portion of our apparatus as described above. Among the sources that utilize lasers, visible light for LV sources as well as IR for desorption sources are provided by Nd:YAG lasers. Ultraviolet photons are provided by both Nd:YAG and excimer lasers, whereas the excitation wavelengths for RET experiments come from two Nd:YAG-pumped dye lasers.
Documentation of Air Emissions Source Term for Radionuclide NESHAP Compliance: TA-53 Building 0984 Isotope Production Facility
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.