National Emission Standards for Hazardous Air Pollutants – Radionuclide Emissions Calendar Year 2020
The U.S. Department of Energy (DOE), National Nuclear Security Administration Nevada Field Office (NNSA/NFO) operates the Nevada National Security Site (NNSS) and the North Las Vegas Facility (NLVF). From 1951 through 1992, the NNSS was the continental testing location for U.S. nuclear weapons. Radionuclides in air from NNSS activities have been monitored since the initiation of atmospheric testing. After 1962, testing was limited to underground detonations, which greatly reduced radiation exposure to the public. Since the end of nuclear testing in 1992, radiation monitoring has focused on detecting airborne radionuclides from historically contaminated soils because this sources dominates the potential offsite dose. These radionuclides are derived from re-suspension of soil (primarily by wind) and emission of tritium-contaminated soil moisture through evapotranspiration. Low amounts of legacy-related tritium are also emitted to air at the NLVF, an NNSS support complex in North Las Vegas. To protect the public from harmful levels of manmade radiation, the Clean Air Act, National Emission Standards for Hazardous Air Pollutants (NESHAP), specifically the National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities (40 CFR 61, Subpart H, 2020) limits the release of radioactivity from a DOE facility to that which would cause 10 millirem per year (mrem/y) effective dose equivalent (EDE) to any member of the public. This limit does not include radiation unrelated to NNSS activities. Unrelated doses could come from naturally occurring radioactive elements, from sources such as medically or commercially used radionuclides, or from sources outside of the United States, such as Japan’s Fukushima nuclear power plant, which was damaged in 2011. NNSA/NFO demonstrates compliance with the NESHAP limit by reporting environmental measurements of radionuclide air concentrations at critical receptor locations on the NNSS. This alternative was proposed and formerly submitted to the U.S. Environmental Protection Agency (EPA) in 2001 (EPA 2001a) and has been the method used to demonstrate compliance with the 40 CFR 61.92 dose standard since 2005. Six locations on the NNSS have been established to act as critical receptor locations to demonstrate compliance with the NESHAP limit. These locations are closer to radionuclide releases than where the public resides so they act as protective substitutes for public receptor locations. Compliance is demonstrated if the measured annual average concentration is less than the NESHAP Concentration Level (CL) for Environmental Compliance listed in Table 2 of 40 CFR 61, Appendix E. For multiple radionuclides, compliance is demonstrated when the sum of the fractions (determined by dividing each radionuclide’s concentration by its CL and then adding the fractions together) is less than 1.0. The EPAapproved air transport model, called the Clean Air Package 1988 (CAP88-PC) is also used to calculate the effective dose equivalent to the maximally exposed individual from NNSS air emissions. CAP88-PC was also used to calculate the population dose, or the collective EDE (expressed as person-rem [roentgen equivalent man] per year [person-rem/y]) for all individuals combined who reside within 80 kilometers (km) of NNSS emission sources. In 2020, the potential dose from radiological emissions to air from both current and past NNSS activities was well below the 10 mrem/y dose limit. This is demonstrated by both the air sampling data collected at critical receptor air monitoring stations and CAP88-PC modeling. The average concentrations of radioactivity at air critical receptor stations ranged from 0.2% to a maximum of 4.2% of the allowed NESHAP limit. CAP88-PC modeling of all 2020 NNSS radionuclide emissions showed the maximally exposed individual to be in Amargosa Valley and this individual received a potential dose of 0.063 mrem/y. The collective dose was calculated to be 0.29 person-rem/year for the 521,300 people who lived within 80 km of NNSS emission sources.