Independent Review of Paducah Gaseous Diffusion Plant Freon Release Authorized Limits and Evaluation of Corresponding Radiological Doses
The Portsmouth/Paducah Project Office (PPPO) proposes to use the American National Standard Institute (ANSI)/Health Physics Society (HPS) N13.12 (ANSI 2013) volumetric screening levels as Authorized Limits (ALs) for the release of cryofluorane R-114 (Freon) at the Paducah Gaseous Diffusion Plant (PGDP) in Paducah, Kentucky. A review of the proposed ALs document indicated that potential exposure scenarios from the release of Freon are adequately discussed therein. However, questions arose regarding the assumptions made for the ANSI N13.12 clearance values, and whether or not all pathway doses were adequately considered in the Authorized Limits Request. For example, PPPO used the inverse square rule to estimate dose to the truck driver. A more appropriate evaluation would have considered the material as a cylindrical source for this pathway. In addition, the inverse square rule was inadequately applied to the inhalation and ingestion pathways. Furthermore, while the ANSI N13.12 volumetric clearance values are used in the ALs, questions arose concerning whether the values are appropriate for materials of greater than 1 metric ton, and whether or not the ANSI N13.12 standard could be used for liquids that are sent to an incinerator. For these reasons, dose modeling was conducted to demonstrate that using ANSI/HPS N13.12 screening levels as ALs for release of PGDP Freon meets the dose criteria set in U.S. Department of Energy (DOE) Order 458.1. This report provides a bounding dose analysis using scenarios described in PPPO document. Realistic parameters, such as the incinerator characteristics data, are used when available.