To: Joni Arends
A number of issues have come up in the course of review of the documents regarding estimation of doses from unmonitored sources. This will provide a formal record of the issues that IEER believes that the ITAT should review, though Justin Mohler has notes on most (all?) of these items already. "We have testimony from whistleblowers documenting the lab's intentional violations of the Clean Air Act air emissions requirements, evidence that the lab willfully ignored problems and violations, and a history of continuous violations since 1990 which even the lab has admitted," stated Jay Coghlan, program director for Concerned Citizens for Nuclear Safety (CCNS), the Santa Fe-based nuclear safety citizens group which brought the suit against LANL, which emits plutonium and other long-lived radionuclides to the air. I. Quality assurance relating to input data The most important item that has arisen, in my view, is the issue of the quality of the data provided to MAQ by the users of radionuclides. It is the responsibility of the user to provide accurate data. MAQ does not do quality assurance on this data and, it seems, does not regard this as part of its mandate. This is a reasonable point of view. Yet, it is crucial that the data that MAQ gets are QA-ed. My understanding is that MAQ does not at present make sure that the data provided by users have gone through a QA process that can, if necessary, be verified. MAQ does not require the maintenance of QA records for this data and does not maintain any records, formal or informal, of any QA to which the data might have been subjected by the user. Some specific items that came up during the review of the files indicate that QA procedures may be lacking at the users' end at least in some cases. 1. The plutonium usage data at 21-257. The data that MAQ got from the user were felt to be too high by MAQ and were sent back for a check. The numbers that came back were different and lower. 2. In the case of TA 48-1, Room 430, ES-67, MAQ requested documentation and got back slightly different (and lower) estimates for Pu usage. 3. At TA 48-1, Room 430, Stack ES-67, plutonium in liquid form is heated. The usage is estimated at 1.5 percent of the amount processed because it is estimated that 98.5% of the Pu is recovered. MAQ does not have a record of the details of how this estimate of recovery was made or of the QA procedures for it. These examples indicate that QA procedures may be lacking for some or all of the user supplied data. Of course, input data that have not been subject to QA would vitiate the validity of all the subsequent calculations, however carefully the calculations are done and QA-ed. IEER recommends that the ITAT should inquire into the QA procedures for the input data at the useršs end as a very high priority. If the ITAT finds that there is not a user data QA process as a matter of normal practice, the ITAT should evaluate the implications of such a deficiency for the compliance status of LANL with respect to Subpart H. II. Other issues 1. Have there been any DU fires or U fires in the places where DU or other U metal is being processed? This is not a question that the MAQ section asks. The ITAT should examine whether fires have occurred and how such issues should be handled. Areas where this may be important are U metal machining and foundry operations (e.g. TA-3 102, ES-25 and TA-3-66, ES-4). 2. The criterion for the emissions reduction factor is whether or not the DU is heated using an external heat source. However, DU is also heated during machining. The ITAT should consider whether the criterion for selection of an emissions reduction factor should depend on external heating or on whether the DU (or other U) actually becomes hot either by heating or through machining or other mechanical processing. In the latter case, using the example of TA 3-102, the emissions factor for machining should be 10-3 rather than 10-6. 3. Is the DU inventory at LANL from virgin or recycled U? If the latter, are there specs for the DU as to trace contaminants? The ITAT should review this issue and examine whether any change is needed in MAQ assessment. 4. The liquid emission reduction factor (unheated) is 10-3. Does this take into account mechanical agitation and the increase in emissions due to mechanical suspension of fine particles? Example 21-257. 5. The ITAT should review the procedures by which the MAQ assures itself that usage of inventories that have not been used for some time (and therefore not reported to MAQ) is reported if and when they do come into use. The thresholds of material accounting in the buildings and rooms for radionuclides should be assessed as part of this review. 6. TA 48-1 Room 430, ES-67 has a liquid DU source that is heated sealed. MAQ assumes that no emissions are occurring. The ITAT should review the reasonableness of this assumption by inquiring into the nature of the sealing that is employed. 7. In some, but not all, cases Pu-239 specific activity is assumed to be that for pure Pu-239. This means that total Pu may be somewhat underestimated in these cases since Pu-240 is being ignored. The ITAT should examine the issue of the Pu-240 content of the Pu-239 and the criteria for using mixed isotopic specific activity or single isotope specific activity. 8. The total radionuclide content of the waste drums that are examined and characterized in TA-54-36 is reported to a high degree of accuracy and small amounts of individual radionuclides. The ITAT should examine the quality of this data in relation to the characterization procedures that are being used. The ITAT should also examine whether the data have been subjected to QA procedures. cc: John Till (at Joni Arends request)
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