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Fuehne, David Patrick

Publications and source records attributed to Fuehne, David Patrick.

At least 19 records

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.

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Stack Test Summary for TA-59-0001

The Radioactive Air Emissions Management (RAEM) team performed stack flow characterization tests at Technical Area (TA) 59 Building 0001 Exhaust Stack (ES) 8. These tests were completed in accordance with Title 40 of the Code of Federal Regulations (CFR), Part 61, Subpart H and the American National Standards Institute (ANSI) N13.1-1999 required by the Clean Air Act. Subpart H of the regulation is the National Emission Standards for Hazardous Air Pollutants (NESHAP) for radionuclides, which compliance with is maintained by the REAM team.

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Notice of Submittal – 2023 Radionuclide Air Emissions Report for Los Alamos National Laboratory

This report describes the emissions of airborne radionuclides from operations at Los Alamos National Laboratory (LANL) for calendar year 2023 and the resulting off-site dose from these emissions. This document fulfills the requirements established by the National Emissions Standards for Hazardous Air Pollutants in 40 CFR 61, Subpart H – Emissions of Radionuclides other than Radon from Department of Energy Facilities, commonly referred to as the Radionuclide NESHAP or Rad-NESHAP. Compliance with this regulation and preparation of this document is the responsibility of LANL’s Rad NESHAP compliance program, which is part of the Environmental Protection and Compliance (EPC) Division. The information in this report is required under the Clean Air Act and is being submitted to the U.S. Environmental Protection Agency (EPA) Headquarters and EPA Region 6. The highest effective dose equivalent (EDE) to an off-site member of the public was calculated using procedures specified by the EPA and described in this report. LANL’s EDE was 0.43 for 2023. The annual limit is 10 millirem per year, established by the EPA in 40 CFR 61 Subpart H. All measured air emissions are modeled to a single location, known as the Maximally Exposed Individual (MEI). During calendar year 2023, LANL continuously monitored radionuclide emissions at 28 “major” release points, or stacks. The Laboratory estimates emissions from an additional 59 “minor” release points using radionuclide usage source terms in lieu of stack monitoring. Also, LANL uses an EPA approved network of air samplers around the Laboratory perimeter to monitor ambient airborne levels of radionuclides. To provide data for dispersion modeling and dose assessment, LANL maintains and operates several meteorological monitoring towers. From these various systems, a comprehensive evaluation is conducted to calculate the MEI dose for the Laboratory. The MEI can be any member of the public at any off-site location where there is a residence, school, business, or office. In 2023, this MEI location was a business at 129 New Mexico State Road 4 (NM-4), located in the northern end of White Rock. The primary contributors to the off-site dose at this location are the ambient air data at that location combined with the collected potential emissions from unmonitored (minor) sources. Overall, the MEI dose in 2023 is similar to that which has been observed in recent years, and it remains well below the EPA’s 10 millirem per year limit. Doses reported to the EPA for the past 10 years are shown in Table E1.

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Summary of Stack Tests at TA-16-Bldg 205: Horizontal Duct on WETF Roof

In late 2023 and early 2024, testing was done at the Weapons Engineering Tritium Facility (WETF) rooftop exhaust duct to verify that the stack sample location was in compliance with the ANSI standard for stack sampling, ANSI N13.1-1999. This ANSI standard is called out by the Clean Air Act rules for airborne radionuclide emissions from DOE facilities, 40 CFR 61 Subpart H. This sample location is designated 16020504, indicating Technical Area 16, Building 0205. The rooftop duct formerly discharged to Exhaust Stack 04, but in 2007 it was re-routed to exhaust out Building 0450, Exhaust Stack 05. For continuity, we have kept the 16020504 designation to represent this duct sample location.

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Environmental Air Monitoring at LANL: 2023 External Program Assessment [Slides]

Radioactive Air Emissions Management evaluates radiological impacts of LANL operations on members of the public, identifies and quantifies releases, and assesses impacts. It is not directly affiliated with cleanup operations or programmatic work and has independent oversight. The focus areas in Environmental Compliance Programs are stack emissions measurements, ambient air measurements, minor source operations evaluations, data management and quality assurance, collaboration with Meteorology program, and collaboration with Dose Assessment program (EPC-ES).

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Evaluation of Minimum Detectable Activities for Stack Sample Analyses

The Rad-NESHAP program takes samples at major point sources to track how much of select nuclides are being emitted out of the stack. Samples are taken at the site where the radiological operations are being performed. The samples are then sent to analytical laboratories for analysis to determine what nuclides exist in the sample. However, due to the sensitivity of the instruments, false positives are often reported. To reduce the number of false positives, the results reported from the analytical labs are compared to set detection limits. Anything below the set detection limit is considered part of the background while anything above the limit is considered a positive hit. Therefore, the detection limit must be set low enough that any false negatives do not result in a significant dose missed at the end of the year but high enough that there are not enough false positives to skew the annual dose being reported. All detection limits listed in this section for the analyses below were designed to meet the stated equivalent emissions rate and subsequent off-site doses. These minimum detectable activities (MDAs) were developed in the 1990s and documented in the memo cited for each analysis below. These limits and memos are all currently referenced in the Quality Assurance Project Plan (QAPP) for the Rad-NESHAP Compliance Task, which is being updated to a Project Implementation Plan (PIP) concurrently with this document. As part of this update process, the original MDAs defined in this section needed to be verified that they were still conservative and meet the off-site dose levels stated.

2019 MDA↗

2022 LANL Radionuclide Air Emissions Report (Rev. 2)

This report describes the emissions of airborne radionuclides from operations at Los Alamos National Laboratory (LANL) for calendar year 2022 and the resulting off-site dose from these emissions. This document fulfills the requirements established by the National Emissions Standards for Hazardous Air Pollutants in 40 CFR 61, Subpart H – Emissions of Radionuclides other than Radon from Department of Energy Facilities, commonly referred to as the Radionuclide NESHAP or Rad-NESHAP. Compliance with this regulation and preparation of this document is the responsibility of LANL’s Rad NESHAP compliance program, which is part of the Environmental Protection and Compliance (EPC) Division. The information in this report is required under the Clean Air Act and is being submitted to the U.S. Environmental Protection Agency (EPA) Headquarters and EPA Region 6. The highest effective dose equivalent (EDE) to an off-site member of the public was calculated using procedures specified by the EPA and described in this report. LANL’s EDE was 0.45 for 2022. The annual limit is 10 millirem per year, established by the EPA in 40 CFR 61 Subpart H. All measured air emissions are modeled to a single location, known as the Maximally Exposed Individual (MEI). During calendar year 2022, LANL continuously monitored radionuclide emissions at 27 “major” release points, or stacks. The Laboratory estimates emissions from an additional 34 “minor” release points using radionuclide usage source terms in lieu of stack monitoring. Also, LANL uses an EPA approved network of air samplers around the Laboratory perimeter to monitor ambient airborne levels of radionuclides. To provide data for dispersion modeling and dose assessment, LANL maintains and operates several meteorological monitoring towers. From these various systems, a comprehensive evaluation is conducted to calculate the MEI dose for the Laboratory. The MEI can be any member of the public at any off-site location where there is a residence, school, business, or office. In 2022, this MEI location was a business at 95 Entrada Drive, located in the eastern end of Los Alamos town site. The primary contributors to the off-site dose at this location are the ambient air data at that location combined with radioactive gas emissions from the LANSCE facility and the collected potential emissions from unmonitored (minor) sources. Overall, the MEI dose in 2022 is similar to that which has been observed in recent years, and it remains well below the EPA’s 10 millirem per year limit. Doses reported to the EPA for the past 10 years are shown in Table E1.

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Review of New or Modified Radioactive Air Emission Sources

This Environmental Protection and Compliance (EPC), Compliance Programs (CP) Quality Procedure (QP) describes the process for review and evaluation of new and modified sources of radioactive air emissions to determine the requirements for pre-construction approval, stack monitoring, stack sampling system upgrade, ambient air monitoring, and the implementation of As Low As Reasonably Achievable (ALARA) principles. These requirements are specified in 40 CFR 61 Subpart H and by DOE Order 458.1, Radiation Protection of the Public and the Environment.

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2021 Radionuclide Air Emissions Report for Los Alamos National Laboratory, Revised October 2022

Provided is a revision to the Calendar Year 2021 Radionuclide Air Emissions Report for the Los Alamos National Laboratory (LANL). This report is a regulatory compliance deliverable for LANL under the Radionuclide NESHAP, 40 CFR 61 Subpart H. The revised report is needed to correct an error identified regarding generation of wind data files. These wind data files are used for plume modeling as part of calculating off-sites doses from monitored radionuclide air emissions sources. The error resulted from a software update by LANL’s meteorology team after new towers were added to the tower network. As a result of this error, incorrect wind frequencies were assigned to the different stability classes. This slightly affected the plume model calculations and subsequent off-site dose determinations for analyses using these wind files.

2021 Radionuclide, Air Emissions↗

Supplemental Information Regarding the Application for Remediation of the Flanged Tritium Waste Containers at Los Alamos National Laboratory

This letter is in response to the October 18, 2021 letter from David Gray, Acting Regional Administrator, to Mr. Theodore Wyka, Manager of the National Nuclear Security Administration’s Los Alamos Field Office (NA-LA). That letter requested additional information regarding the Application for remediation of the Flanged Tritium Waste Containers (FTWCs) at Los Alamos National Laboratory (LANL) Technical Area 54, Area G. The Emissions Management Plan for the FTWC Venting Project is attached.

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Notice of Submittal – 2020 Radionuclide Air Emissions Report for Los Alamos National Laboratory

Enclosed is the Calendar Year 2020 Radionuclide Air Emissions Report for the Los Alamos National Laboratory (LANL). The submittal is in compliance with 40 CFR 61 Subpart H. The highest effective dose equivalent to any member of the public from LANL operations in 2020 is 0.29 millirem. This maximally exposed individual location is a business at 132 DP Road, Los Alamos, NM. The annual dose is well below the EPA standard of 10 millirem per year as established in Subpart H.

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Annual Performance Testing of Tracer Gas and Tracer Aerosol Detectors for use in Radionuclide NESHAP Compliance Testing

Los Alamos National Laboratory’s (LANL’s) compliance with Radionuclide NESHAP 1 regulations is managed by the Radionuclide Air Emissions Management (RAEM) team, part of LANL’s Compliance Programs group (EPC-CP). One area of the Radionuclide NESHAP addresses requirements for siting a stack sample system. This memo documents the most recent performance tests of the sulfur hexafluoride detectors for use in stack gas mixing tests, as well as the functional trending test on a pair of optical particle counters, comparing results from a non-calibrated instrument to a calibrated instrument.

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2019 LANL Radionuclide Air Emissions Report

In June 2020, Los Alamos National Laboratory (LANL) submitted letter ESHQSS: 20-025 to Region 6 of the Unites States Environmental Protection Agency (EPA). This letter transmitted the 2019 LANL Radionuclide Air Emissions Report to the EPA. This report summarizes LANL operations, air emissions of radionuclides, and subsequent off-site dose consequence from these emissions for calendar year 2019. This report is issued to meet requirements of 40 CFR 61 Subpart H, National Emission Standards for Emissions of Radionuclides other than Radon from Department of Energy Facilities. This regulation, called the Radionuclide NESHAP, establishes a limit of 10 millirem per year to the maximally exposed member of the public and requires an annual report to be submitted to the appropriate EPA Region by June 30th of each year. LANL’s off-site dose from airborne emissions of radionuclides in 2019 was 0.43 millirem. The normal practice is to issue this report directly to EPA Region 6 in June of each year, and then after the report is accepted by the EPA, re-issue the report for inclusion in the LANL Electronic Public Reading Room (EPRR). This second part is usually done in July of each year, but this step was overlooked in July 2020 due to other commitments. We regret this error. This omission was noted in late 2020; we are submitting the 2019 LANL Radionuclide Air Emissions Report to the EPRR now in December 2020. Aside from the addition of this cover sheet explaining the delay, the report is unchanged from the version submitted to EPA Region 6 in June.

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Using the CAP88 Plume Model & Dose Assessment Code for the FTWC Project

The Environmental Protection & Compliance Division (EPC) uses the Clean Air Act Assessment Package – 1988 (CAP88) plume model and dose assessment code to evaluate measured emissions or projected emissions of airborne radionuclides from Los Alamos National Laboratory (LANL) facilities. This software package will use facility data (e.g., stack height and exit velocity), emissions parameters (chemical form and quantity), and environmental data (wind speed and direction) to predict downwind concentrations of radioactive material and subsequent dose to a member of the public at that location. The United States Environmental Protection Agency (EPA) has approved CAP88 for use in demonstrating compliance with the Radionuclide NESHAP2, that portion of the Clean Air Act addressing emissions of airborne radioactive material from Department of Energy facilities. EPC Division has two procedures which discuss the use of CAP88.

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Evaluation of FTWC Vent System

A monitored exhaust system has been designed for use in venting the Flanged Tritium Waste Containers (FTWCs) at LANL. This system will provide controlled exhaust and emissions monitoring for the FTWCs, and also provide general area exhaust around the venting operations to measure any emissions which may bypass the primary vent system. A full description of the process and need for the system is described in the Pre-Construction Application for this project. This document describes the commissioning testing performed on the FTWC vent system to prepare it for use. The system has been tested and shown to meet ANSI standard requirements and is fully suitable for use.

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Notification of Operational Scope Change for the FTWC Venting Project at Los Alamos National Laboratory (LANL)

This letter is intended to provide you an update on the scope of work for the venting of the Flanged Tritium Waste Containers (FTWCs) at Los Alamos National Laboratory (LANL) Technical Area (TA-) 54. This project was described in the Application for Pre-Construction Approval 1 ("the Application") that was approved by EPA Region 6 on May 22, 2019. As operational planning for this project has been finalized, the scope of work described in the Application has slightly changed. The project has now determined that each FTWC may be vented multiple times, and these venting activities may take place at more than one location. The original application only discussed a single venting operation for each FTWC at a single location, TA-54. However, the radionuclide inventory and expected air releases remain bounded by the values described in the Application.

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Protocol for Determining Actual Flow Rate in FTWC Duct Systems

This paper is intended to document the theory and methods to determine the actual flow rate in the exhaust system used to ventilate the Flanged Tritium Waste Containers based on realtime instrument readings. Section 1 provides introductory and background material; Section 2 details the various correction factors used to adjust flow readings for ambient air pressure and temperature and other operational parameters. Section 3 provides guidance on implementing this process during venting operations, and Section 4 provides supporting documentation and also a field checklist that can be used by personnel during venting. For Revision 1, a summary of editorial changes made to the paper was added as Section 4.4, as well as a section documenting peer review (Section 4.5).

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2018 Annual Site Environmental Report

Los Alamos National Laboratory’s (the Laboratory’s) annual site environmental reports are prepared annually by the Laboratory’s environmental organizations, as required by U.S. Department of Energy Order 231.1B, Administrative Change 1, Environment, Safety, and Health Reporting, and Order 458.1, Administrative Change 3, Radiation Protection of the Public and the Environment. The following chapters in this report discuss our success in complying with environmental laws, regulations, and orders (Chapter 2, Compliance Summary); how we manage the Laboratory’s environmental performance (Chapter 3, Environmental Programs); how we monitor for air emissions of radioactive materials and climate conditions (Chapter 4, Air Quality); how we monitor for effects of Laboratory operations on groundwater quality (Chapter 5, Groundwater Monitoring); how we monitor the movement of chemicals and radionuclides by storm water runoff and the levels of chemicals and radionuclides in deposited sediment (Chapter 6, Watershed Quality); how we monitor for the presence, levels, and effects of chemicals and radionuclides in plants, animals, soil, and vegetation (Chapter 7, Ecosystem Health); and finally, what radionuclide dose or risk from chemical exposure members of the public may experience as a result of Laboratory operations (Chapter 8, Public Dose and Risk Assessment). This report follows plain language guidelines, as required for federal agencies by the Plain Language Act of 2010. More information about plain language can be found at http://www.plainlanguage.gov/index.cfm. You will notice we have substantially reduced the use of acronyms and abbreviations and are using active voice and personal pronouns. We hope you find this report useful. If you have suggestions for improving this report, additional questions, or want a copy of this report, please contact us at envoutreach@lanl.gov, or call the Communications Office at 505-665-7000. This report, its supplemental tables, and the 2018 Annual Site Environmental Report Summary are available at http://www.lanl.gov/environment/environmental-report.php. Note: This document has been revised since it was initially published on September 23, 2019. The revisions included corrections to figure and table references, changes in heading levels, adding blank pages where appropriate, and changes of an editorial nature.

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