Incinerator effluents

[mandel (Hector Mandel)]

Patrick, my guess is that you really do not have a dilemma.  The  
average annual concentration at the point of release is not a  
function of flow rate in the incinerator stack.  You are probably  
basing your calcualtions on the concentration at the point of release  
only during periods when the incinerator is in operation.  To  
calculate the average annual concentration, you also need to average  
in the concentraion during the times that the incinerator is NOT  
operating.  After all, the hypothetical individual who has his head  
stuck in your stack is there ALL YEAR :) .  All you have to show the  
NRC is that the ACTUAL average concentration on the rooftop a few  
feet away from the stack is below the effluent limit listed in the  
regs.  To do that, you can assume a ground level release and only the  
TOTAL release over a one year period affects the outcome.  If you  
neglect effective stack height, the flow rate has no bearing on the  
calculation.  The calculations are easy enough and the NRC has no  
reason to refuse granting you a request to base your effluent limits  
on total activity released from the stack as opposed to  
concentrations in the effluent during incinerator operation.  The  
former method is somewhat less concervative in terms of calculating a  
dose to the hypothetical individual.  On the other hand, the latter  
method is WRONG.  :-)


============== Original message =========		
	  With our current stack air flow we use approximatly 50% of  
our annual
          effluent with the existing Part 20 values. New part 20  
values
	  raise this to over 1200 % for the year. We are also
	  recalculating the stack air flow but preliminary fiqures 

          show only a doubling of volume.

So basically its not the ash that is the problem it is the effluent
restrictions. We are looking at having to decay over 200 40lb dogs  
for
about six months if things stay as they are. This would call for a  
$20,000
investment for a freezer large enough.... Hench our dilemma