NORM in Coal - U.S. DOE EIS on a coal plant

[Donivan Porterfield <radchem@zilker.net>]

There have been some comments of late about the presence of NORM in coal plants
emissions and coal ash.  These comments high-lighting the sense to which NORM emissions
are comparitively ignored for coal plants.  For those of that opinion an opportunity
presents itself to drive home that point a bit.

U.S. DOE has recently published a notice of intent (NOI) to prepare an environmental
impact statement (EIS) on the Kentucky Pioneer Integrated Gasification Combined Cycle
Demonstration Project, Trapp, KY.  The Federal Register citation being Vol. 65, No. 73,
Friday, April 14, 2000; pg 20142-20145.  This plant consuming both coal and municipal
solid waste in its feed stream.

Written comments on the proposed EIS scope should be addressed to: Mr. Roy Spears, NEPA
Document Manager for the Kentucky Pioneer IGCC Demonstration Project, National Energy
Technology Laboratory, U.S. Department of Energy, 3610 Collins Ferry Road, Morgantown,
WV 26507–0880.  These comments must be recieved by 31 May 2000 to assure
consideration.  Mr. Spears can be contacted directly at: telephone 304–285–5460; toll
free telephone 1–800–432–8330 (extension 5460); fax 304–285–4403; or e-mail
rspears@netl.doe.gov.

As an example of how DOE addresses NORM in coal plants, below is content from the draft
of EIS-0289, “Draft Environmental Impact Statement for the JEA Circulating Fluidized
Bed Combustor Project":
*****************
Fossil fuels and limestone contain trace quantities of naturally occurring
radionuclides, primarily uranium-238, thorium-232, and their decay products. During the
burning of fossil fuels, inert material either falls to the bottom of the combustor as
bottom ash or becomes entrained in the gaseous combustion products as fly ash. This ash
contains radionuclides originally present in the fuel and/or limestone. Fly ash not
captured by pollution control equipment is emitted into the atmosphere as particulate
matter. In addition, two radioactive noble gases, radon-220 and radon-222, are emitted
from the combustor as gases. The quantities of naturally occurring radionuclides vary
according to fuel type and its geographical location; coal typically contains the
greatest total quantity per unit mass.

For a proposed facility very similar to the proposed project, detailed dose pathway
analyses were performed for radionuclides in coal and limestone using two different
approaches: measurement of radioactive species at an operating plant (Weston 1995) and
calculations based on coal analysis coupled with emission factors (DOE 1995). The
estimated radionuclide emission rates for the similar facility were approximately 10
times greater than the estimated radionuclide emission rates of 6 mCi/year for the
proposed project. Not including radon gas, a lifetime cancer risk to the maximum
exposed person in a range of 2 in 10 million (2 ื 10E-7 ) to 2 in 1 million (2 ื 10E-6
) was obtained using the two approaches. Given that emissions from the proposed project
would be about 10 times lower and that typical risks would be proportionally lower, the
lifetime cancer risk for the maximum exposed person would be in the range of 2 in 100
million (2 ื 10E-8 ) to 2 in 10 million (2 ื 10E-7 ).

Because radon is a noble gas that is not captured in particulate filters, it is often
treated separately.  Using an upper limit for radon of approximately 175 mCi/year (DOE
1995) and an estimated dilution at the location of maximum exposure of about 6 ื 10E-9
s/m3 (the ratio of the maximum annual ground level concentration in the ambient air
calculated by the ISCST3 air dispersion model to the air emission rate), the dose is
estimated to be approximately 3 ื 10E-4 urem per year, which is a lifetime risk of 1 in
100 billion (1 ื 10E-11 ) (ICRP 1991).
*****************

Those wanting to see DOE address the NORM in coal with greater detail may well be able
to drive by asking for such as part of the EIS scoping process.


Donivan Porterfield
PO Box 1417
Los Alamos, NM  87544
radchem@zilker.net


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