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Methods to Track Effective Doses from Airborne Radioactive Emissions for Compliance with 40 CFR 61, SUBPART H

US Department of Energy national laboratories can play an integral role in not only the advancement of science but also in the treatment of various medical conditions through research and development activities conducted at radioisotope production facilities. Here, a project has been underway at Oak Ridge National Laboratory since 2016 whose mission is to produce and supply the radioisotope 227 Ac, which is used in a radiopharmaceutical developed to treat certain types of prostate cancer and bone metastases. Production activities result in the environmental release of airborne radioactive emissions, which are governed by Clean Air Act regulations described in 40 CFR Part 61, Subpart H. Stack 3039, the source that emits radioactive effluents from 227 Ac production, is subject to additional requirements outlined in American National Standards Institute (ANSI) N13.1-1969 due to its grandfathered status. Radioactive emissions are limited to levels below those that would cause annual compliance dose standards for members of the public to be exceeded and stack 3039 to lose its grandfathered status. To allow for maximum production of 227 Ac without exceeding relevant dose limits, monthly tracking of project emissions and resulting CAP88-PC modeled effective doses to a maximally exposed individual have been implemented. Four years of tracking data were compiled and analyzed to identify additional methods that could be used to estimate project doses more frequently, potentially further optimizing 227 Ac production while maintaining compliance with applicable regulations.

atmospheric emissions

Idaho National Laboratory CY 2025 National Emission Standards for Hazardous Air Pollutants Analysis, Methodology, and Results for Radionuclides

This report details calculations of potential dose—at public receptor locations surrounding the Idaho National Laboratory (INL) Site boundary and INL in-town facilities—from radionuclides reported to be in use and potentially emitted from INL facilities during calendar year (CY) 2025. All calculations were performed in accordance with the requirements of Code of Federal Regulations (CFR), Title 40, “Protection of the Environment,” Part 61, “National Emission Standards for Hazardous Air Pollutants (NESHAPs),” Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” (40 CFR 61, Subpart H). Modeling methodology, model-input parameters, and contribution to dose by facility, source, and radionuclide at the maximally exposed individual (MEI) location are also discussed. The information in this report supports the “National Emission Standards for Hazardous Air Pollutants—Calendar Year 2025 INL Report for Radionuclides” (DOE-ID 2026). During CY 2025, the estimated annual potential dose at the INL Site MEI location was 2.45E-02 mrem/yr, up from the previous year, but remaining far less than the regulatory standard of 10 mrem/yr (CFR 40 Part 61, Subpart H). Approximately 92% of the total dose to the INL Site MEI originated from Materials and Fuels Complex sources. Emissions from INL in-town facilities resulted in an estimated annual potential dose of 4.50E-03 mrem/yr to the MEI, down slightly from the CY 2024 estimated dose. Year-to-year variations in estimated annual dose can be attributed to adjustments in laboratory operations, changes to facility infrastructure, and variation in meteorological conditions.

42 - ENGINEERING

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.

54 ENVIRONMENTAL SCIENCES

Idaho National Laboratory CY 2024 National Emission Standards for Hazardous Air Pollutants Analysis, Methodology, and Results for Radionuclides

This report documents the methodology and results for calculating the effective dose equivalent (EDE) to the maximally exposed individual (MEI) from atmospheric radionuclide emissions from Idaho National Laboratory (INL) sources in Calendar Year (CY) 2024. The calculations were performed in accordance with requirements in Code of Federal Regulations (CFR), Title 40, “Protection of the Environment,” Part 61, “National Emission Standards for Hazardous Air Pollutants (NESHAPs),” Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” (40 CFR 61, Subpart H). UDFs were calculated using the computer model CAP88-PC for unit (1 Ci/yr) emission rates at INL Site facilities and INL in-town (Idaho Falls) facilities and stored in Microsoft Access databases. The UDFs—in this case, mrem/Ci—were then combined with radionuclide-specific release (emission) rates for each facility-specific source to compute doses at predetermined public receptor locations, including the MEI locations. This report contains the dose results and a description of the methodology and tools used to compute the doses.

07 - ISOTOPES AND RADIATION SOURCES

PNNL-Richland Campus Radionuclide Air Emissions Report for Calendar Year 2023

This report documents radionuclide air emissions that result in the 2023 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The dose to the PNNL-Richland campus MEI from routine emissions sources, excluding radon, in 2023 from campus sources is 2.0E-5 mrem (2.0E-7 mSv) EDE. The dose from radon emissions is 4.0E-7 mrem (4.0E-09 mSv) EDE. No nonroutine emissions occurred in 2023. The total radiological dose to the MEI from all PNNL-Richland campus radionuclide emissions, including fugitive emissions and radon, is 2.1E-5 mrem (2.1E-7 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL-Richland campus is in compliance.

40 CFR 61 Subpart H

PNNL-Richland Campus Radionuclide Air Emissions Report for Calendar Year 2024

This report documents radionuclide air emissions that result in the 2024 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The total dose to the MEI from all PNNL-Richland campus radionuclide emissions in 2024, including fugitive emissions and radon, is 1.3E-05 mrem (1.3E-07 mSv) EDE, or 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland campus is in compliance. The dose attributable to radon emissions is 4.1E-10 mrem (4.1E-12 mSv) EDE.

40 CFR 61 Subpart H

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2025

This report documents radionuclide air emissions that result in the 2025 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The total dose to the MEI from all PNNL Richland Campus radionuclide emissions in 2025, including fugitive emissions and radon, is 1.8E-05 mrem (1.8E-07 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance. The dose attributable to radon emissions is 1.5E-13 mrem (1.5E-15 mSv) EDE.

40 CFR 61 Subpart H

Determining Unabated Airborne Radionuclide Emissions Monitoring Requirements Using Inventory-Based Methods

Compliance with the airborne radionuclide emission monitoring requirements in the National Emission Standards for Hazardous Air Pollutants (NESHAP; Title 40 of the U.S. Code of Federal Regulations Part 61, Subpart H) and State requirements in Washington Administrative Code 246–247: Radiation Protection – Air Emissions and 173-480: Ambient Air Quality Standards and Emission Limits for Radionuclides were evaluated for Pacific Northwest National Laboratory (PNNL) operations. Additional guidance may be found in the U.S. Department of Energy Handbook, Environmental Radiological Effluent Monitoring and Environmental Surveillance. To meet regulatory requirements, reviews of planned or proposed projects and activities provide the basis for implementing necessary monitoring adjustments or for implementing changes to projects and activities in a timely manner. Potential unabated off-site doses were evaluated for emission locations managed by PNNL and licensed to the Department of Energy. These locations were at facilities in Richland, Washington (i.e., the Hanford Site and PNNL–Richland campus) and in Sequim, Washington, (PNNL–Sequim campus). This report describes the inventory-based methods and provides the results for the NESHAP assessment performed in January 2024 for calendar year ending 2023.

40 CFR 61 Subpart H

EMP, Attachment 2: Data Management Plan

This Data Management Plan (DMP) is an attachment to the Pacific Northwest National Laboratory Environmental Radiological Air Monitoring Plan (EMP). PNNL is a U.S. Department of Energy Office of Science national laboratory. Radioactive effluent monitoring and environmental surveillance for PNNL operations in Washington State are the responsibility of the PNNL Environmental Protection and Regulatory Programs division and are conducted by the Environmental Radiation Task staff. This DMP describes the data management processes for PNNL radioactive air emissions (stack) monitoring and environmental radiological ambient air surveillance activities.

40 CFR 61 Subpart H

Pacific Northwest National Laboratory Annual Site Environmental Report for Calendar Year 2023

Pacific Northwest National Laboratory (PNNL), one of the U.S. Department of Energy (DOE) Office of Science’s 10 national laboratories, provides innovative science and technology development in the areas of energy and the environment, fundamental and computational science, and national security. There are three DOE offices within the Richland area. Two are responsible for the Hanford Site, whereas the Pacific Northwest Site Office oversees PNNL. PNNL prepares an Annual Site Environmental Report to meet the requirements of DOE Order 231.1B, Environment, Safety and Health Reporting, and DOE Order 458.1, Radiation Protection of the Public and the Environment, thus assuring that the public is informed of any PNNL-Richland campus or PNNL-Sequim campus event that could adversely affect the health and safety of the public, site staff, or the environment. The report provides a synopsis of ongoing environmental management performance and compliance activities for operations that occur at the PNNL-Richland campus in Richland, Washington, and at the PNNL-Sequim campus near Sequim, Washington. It describes the location of and background for each facility; addresses compliance with applicable DOE, federal, state, and local regulations, and site-specific permits; documents environmental monitoring efforts and their status; presents potential radiation doses to staff and the public in the surrounding areas; and describes DOE-required data quality assurance methods used for data verification. The ASER report describes Compliance with Federal, State, and Local Laws and Regulations in 2023, Environmental Sustainability, Environmental monitoring and dose assessment, Natural and Cultural Resource Management, and Quality Assurance activities that took place during Calendar Year 2023.

40 CFR 61 Subpart H

EMP, Attachment 1: Sampling and Analysis Plan (Rev.1)

This Sampling and Analysis Plan (SAP) is written for the Environmental Radiation Task activities related to radioactive air emissions (stack) monitoring and environmental radiological ambient air surveillance of Pacific Northwest National Laboratory (PNNL) operations at the PNNL-Richland campus and PNNL-Sequim campus. PNNL is a U.S. Department of Energy Office of Science laboratory in Richland, Washington. This plan is an attachment to PNNL’s Environmental Radiological Air Monitoring Plan (EMP) (PNNL-20919) and addresses a discrete, vital subject area that is subject to revision independent of the main text of the EMP document. This SAP provides the requirements for planning sampling events and the requirements imposed on the services provided by the analytical laboratory to the PNNL Environmental Radiation Task.

40 CFR 61 Subpart H

EMP - Environmental Radiological Air Monitoring Plan: PNNL Operations in Washington

The Environmental Radiological Air Monitoring Plan (EMP) for Pacific Northwest National Laboratory (PNNL) describes systems/processes/practices related to radiological operations in Richland and Sequim, Washington, that are associated with environmental radiological air monitoring and surveillance activities. The activities described support the lab’s responsibility to maintain safe operations and minimize negative impacts to both onsite and offsite persons and environment. Dose assessments required by regulations and DOE Orders for the public and biota are described. PNNL conducts environmental air surveillance monitoring as part of the PNNL Site Radioactive Air Emissions License (RAEL)-005 for Richland Campus, issued in 2010 with its most recent renewal effective in January 2021. The radioactive air emissions license for the PNNL-Sequim campus (RAEL-014) was issued to the U.S. Department of Energy in 2012 with its most recent renewal effective in January 2023. The EMP is a compilation of the following four documents: - Environmental Radiological Air Monitoring Plan (this main document) (PNNL-20919) - Sampling and Analysis Plan (Attachment 1) (PNNL-20919-1) - Data Management Plan (Attachment 2) (PNNL-20919-2) - Dose Assessment Guidance (Attachment 3) (PNNL-20919-3).

40 CFR 61 Subpart H

PNNL Dose-per-Unit-Release Factors for Calculating Radionuclide Emissions Potential-to-Emit Doses

Revised PNNL-Richland campus dose-per-unit release factors based on the Environmental Protection Agency code CAP88-PC Version 4.1.1 code are provided. In addition to maximum receptor dose factors, maximum air concentration dose factors are provided. The PNNL-Sequim campus dose-per-unit release factors are included, as well, based on the Environmental Protection Agency code COMPLY Version 1.7.1.

40 CFR 61 Subpart H

Summary of Analytical Services for the Hanford Site Radionuclide NESHAP Program

This document is a summary of the point source analytical requirements used to demonstrate compliance for the Department of Energy (DOE) Hanford Site operations with 40 Code of Federal Regulations (CFR) Part 61, “National Emission Standards for Hazardous Air Pollutants,” (NESHAP) Subpart H, “National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities,” and the Washington Administrative Code (WAC) 246-247, “Radiation Protection – Air Emissions.” This reference collects information from multiple source documents and is not intended to create, supersede, replace or over-ride any existing contractual, DOE, federal or state statutes, regulations, compliance agreements, orders, permits, licenses or other requirements. The requirement source document governs where any difference may exist. The Hanford Mission Integration Solutions (HMIS) Environmental organization has been contracted by DOE to manage and report data collected from the sampling and monitoring of radioactive air emissions point sources, colloquially called stacks. The Environmental organization coordinates the analyses and reporting of samples collected at various facilities across the Hanford Site. These facilities operate approximately 52 stacks that require sampling, monitoring or estimating radioactive air emissions. The stacks are operated by Bechtel National, Inc. (BNI), Central Plateau Cleanup Company (CPCCo), Hanford Tank Waste Operations & Closure (H2C), Hanford Laboratory Management and Integration (HLMI), and Pacific Northwest National Laboratory (PNNL). Stack samples from CPCCo, HLMI and H2C facilities are collected by the operating contractor staff, delivered to HMIS, and then shipped to an offsite contracted laboratory for analyses. The field and laboratory sample data uploaded into the Sample Management and Analytical Results Tracking (SMART) database are used to calculate sample volumes and concentrations. Sample concentrations are evaluated for compliance with federal and state regulations, permits, and license requirements. The SMART database also calculates total curies released for sampled point sources and stacks. Point source effluent concentrations and releases are published annually in publicly available reports. The BNI and PNNL operate several DOE-Hanford Field Office (HFO) stacks subject to the requirements of 40 CFR 61, Subpart H and WAC 246-247. The concentrations, curies released and dose modeling evaluation for these stacks are included in the DOE-HFO annual radionuclide NESHAP report. The sample collection, analyses and emissions estimates for these stacks are outside the scope of HMIS contracted responsibilities and not addressed further in this document.

54 ENVIRONMENTAL SCIENCES

LLNL NESHAPs 2023 Annual Report

Lawrence Livermore National Security, LLC operates facilities at Lawrence Livermore National Laboratory (LLNL) in which radionuclides are handled and stored. These facilities are subject to the U.S. Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAPs) in Code of Federal Regulations (CFR) Title 40, Part 61, Subpart H, which regulates radionuclide emissions to air from Department of Energy (DOE) facilities. Specifically, NESHAPs limits the emission of radionuclides to the ambient air to levels resulting in an annual effective dose equivalent of 10 mrem (100 µSv) to any member of the public. Using measured and calculated emissions, and building-specific and common parameters, LLNL personnel applied the EPA-approved computer code, CAP88-PC, Version 4.1.1.0, to calculate the dose to the maximally exposed individual member of the public for the Livermore Site and Site 300.

54 ENVIRONMENTAL SCIENCES

PNNL Sequim Campus Radionuclide Air Emissions Report for Calendar Year 2025 : Department of Energy – Office of Science Pacific Northwest National Laboratory

The U.S. Department of Energy Office of Science’s Pacific Northwest Site Office has oversight and stewardship duties associated with the Pacific Northwest National Laboratory Sequim Campus. Facility operations include radiological operations with the potential-to-emit low levels of radioactive materials. This report is prepared to document compliance with the 40 CFR Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities,” and Washington Administrative Code Chapter 246-247, Radiation Protection–Air Emissions. The PNNL Sequim Campus is in compliance with the federal and state 10 mrem/yr standard for 2025 operations.

40 CFR 61 Subpart H

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.

54 ENVIRONMENTAL SCIENCES