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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 2021 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) 2021. All calculations were performed in accordance with the 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). 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 2021 INL Report for Radionuclides” (INL 2022). In CY 2021, the estimated annual potential dose at the INL Site MEI location was 6.67E-02 mrem/yr, up slightly from the previous year, but far less than the regulatory standard of 10 mrem/yr (CFR 40 Part 61, Subpart H). Approximately 97% of the total dose to the INL Site MEI originated from MFC sources. Emissions from INL in-town facilities resulted in an estimated annual potential dose of 6.21E-03 mrem/yr to the MEI, down 40% from the CY 2020 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.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Idaho National Laboratory CY 2022 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) 2022. All calculations were performed in accordance with the 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). 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 2022 INL Report for Radionuclides” (DOE-ID 2023). In CY 2022, the estimated annual potential dose at the INL Site MEI location was 1.78E-02 mrem/yr, down from the previous year, and far less than the regulatory standard of 10 mrem/yr (CFR 40 Part 61, Subpart H). Approximately 87% 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 4.03E-03 mrem/yr to the MEI, down 35% from the CY 2021 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.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

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↗

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.

54 ENVIRONMENTAL SCIENCES↗

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↗

EMP, Attachment 3: Dose Assessment Guidance

This Dose Assessment Guidance (DAG) describes methods used to comply with the reporting requirements for dose to an individual member of the public receptor, collective dose, and biota dose for radionuclide air emissions under the U.S. Department of Energy, Office of Science, Pacific Northwest National Laboratory (PNNL) Environmental Monitoring Plan (EMP). The National Emission Standards for Hazardous Air Pollutants (40 CFR 61), Subpart H, is the greatest driver for the requirements. This DAG applies to public dose from radioactive material releases to the air from PNNL Richland Campus and PNNL Sequim Campus. Dose determinations from Richland Campus surveillance of ambient external dose and ambient air particulates is also briefly discussed. This guidance is Attachment 3 to PNNL’s EMP (PNNL-20919) and addresses a discrete, vital subject area of the EMP that is subject to revision independent of the main text of the EMP document.

40 CFR 61 Subpart H↗

EMP Attachment 3: Dose Assessment Guidance (Rev.3)

This Dose Assessment Guidance (DAG) describes methods used to comply with the reporting requirements for dose to an individual member of the public receptor, collective dose, and biota dose for radionuclide air emissions under the U.S. Department of Energy, Office of Science, Pacific Northwest National Laboratory (PNNL) Environmental Monitoring Plan (EMP). The National Emission Standards for Hazardous Air Pollutants (40 CFR 61), Subpart H, is the greatest driver for the requirements. This DAG applies to public dose from radioactive material releases to the air from PNNL-Richland Campus and PNNL Marine and Coastal Research Laboratory. Dose determinations from Richland Campus surveillance of ambient external dose and ambient air particulates is also briefly discussed. This guidance is Attachment 3 to PNNL’s EMP (PNNL-20919) and addresses a discrete, vital subject area of the EMP that is subject to revision independent of the main text of the EMP document.

40 CFR 61 Subpart H↗

EMP, Attachment 3: Dose Assessment Guidance (Rev.4)

This Dose Assessment Guidance (DAG) describes methods used to comply with the reporting requirements for dose to an individual member of the public receptor, collective dose, and biota dose for radionuclide air emissions under the U.S. Department of Energy, Office of Science, Pacific Northwest National Laboratory (PNNL) Environmental Monitoring Plan (EMP). The National Emission Standards for Hazardous Air Pollutants (40 CFR 61), Subpart H, is the greatest driver for the requirements. This DAG applies to public dose from radioactive material releases to the air from PNNL-Richland campus and PNNL-Sequim campus. Dose determinations from Richland campus surveillance of ambient external dose and ambient air particulates is also discussed. This guidance is Attachment 3 to PNNL’s EMP (PNNL-20919) and addresses a discrete, vital subject area of the EMP that is subject to revision independent of the main text of the EMP document.

40 CFR 61 Subpart H↗

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.

99 GENERAL AND MISCELLANEOUS↗

Assessment of the 3420 Building Filtered Exhaust Stack Sampling Probe Location: Stack Verification Following Fan and Air Blender Additions

The Pacific Northwest National Laboratory (PNNL) 3420 Building, which is part of the Physical Sciences Facility (PSF), houses radiological capabilities that results in the requirement that emissions monitoring must be conducted for potential radionuclides in the exhaust air discharge of this building. The air monitoring system is required to conform to Title 40 of the Code of Federal Regulations part 61 (40 CFR 61) Subpart H, which in turns requires a sampling probe in the exhaust stream to conform to the criteria of American National Standards Institute / Health Physics Society (ANSI/HPS) N13.1-2011, Sampling and Monitoring Releases of Airborne Radioactive Substances from the Stack and Ducts of Nuclear Facilities. To support the air emissions permit for the 3420 Building on the PNNL campus, stack testing that used computational fluid dynamics (CFD) modeling as a surrogate stack and verification tests of velocity uniformity and flow angle on the retrofitted facility stack was performed. The ANSI/HPS N13.1-2011 criteria for the air monitoring probe location are that velocity uniformity, gaseous tracer uniformity, and particulate tracer uniformity must be less than or equal to 20%COV. Furthermore, no point in the sampling location may have a gaseous tracer concentration that varies from the mean concentration by more than 30%. Additionally, the flow angle at the sampling location must not be more than 20°. The CFD modeling of the stack, as reported by Recknagle et al. (2018) demonstrated that the stack meets the criteria at the probe location. The velocity uniformity and flow angle results from the 3420 stack verification tests, performed in October 2020, demonstrated that the CFD model results may be used to support the qualification of the stack sampling location. The measured velocity uniformity verification test result was 1.4%COV. This value is well within the uniformity criterion, which is that the velocity uniformity be =20%COV. Additionally, this value is well within the criterion that the actual stack measurement must be within 5% of the surrogate stack result of 2.1%COV when all four fans were operating. Additionally, the measured average flow angle at the 3420 stack monitor location was 15.5 degrees. Although this is higher than expected based on the CFD model, the result is =20 degrees, so the criterion is met. Based on these stack verification test results, the reconfigured 3420 Building filtered exhaust stack meets the qualification criteria given in the ANSI/HPS N13.1-2011 standard. Further changes to the system configuration or operating conditions that are outside the bounds described in this and the CFD report (Recknagle et al., 2018) may require additional tests and additional analysis to determine compliance with the standard.

3420 Building↗

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.

54 ENVIRONMENTAL SCIENCES↗

Processing Meteorological Data for the CAP-88 PC Model at Los Alamos National Laboratory

The Environmental Protection and Compliance-Compliance Programs (EPC-CP) group at Los Alamos National Laboratory (LANL) uses the Clean Air Act Assessment Package 1988 (CAP-88, Littleton 2020) PC model (Version 4.1) to estimate radiological doses for a set of areal sectors surrounding a release location, in order to satisfy the Environmental Protection Agency (EPA) National Emission Standards for Hazardous Air Pollutants (NESHAP) dose calculation requirement in 40 CFR 61 Subpart H. Among several types of data that must be prepared for CAP-88 input is a text file of meteorological data (“WIND” file), consisting of the joint frequency of wind direction, wind speed, and atmospheric stability categories. EPC-CP produces customized WIND files by running a CAP-88 utility program on a user generated text file of wind data in a different format, known as a STability ARray (STAR) file (Turner, 1964). At LANL, EPC-CP meteorologists prepare customized STAR files with data over desired time periods at selected meteorological towers. A custom program written in Precision Visuals -Workstation Analysis and Visualization Environment (PV-WAVE), a commercial Fortran-like language, is used to read LANL meteorological data and write a STAR file; the executable filename is “Star.out”. However, the outdated PV-WAVE utility program is being phased out by EPC-CP, due to the inefficient process to run it and an inability to modify the code. To preserve the ability to create customized meteorological data for CAP-88 in a way that will be easy to use and maintain, a new replacement utility program, written in the Python programming language, has been developed. The new, improved program reads a data file from any LANL meteorological tower, and at each desired observation time, determines the wind direction, wind speed, and stability categories defined in the CAP-88 documentation. The frequencies of all combinations of the three sets of categories are calculated and written to a file in the STAR format, which can later be converted to a WIND file for input into CAP-88.

54 ENVIRONMENTAL SCIENCES↗

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.

54 ENVIRONMENTAL SCIENCES↗

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↗

Update of Receptor Locations for INL National Emissions Standard for Hazardous Air Pollutants (NESHAP) Assessments

This report documents the selection of updated public receptor locations for use in conducting regulatory assessments of radioactive air emissions for Idaho National Laboratory (INL) facilities. The basis for this receptor location analysis is found in 40 CFR 61 Subpart H, “National Emissions Standards for Emissions of Radionuclide Other than Radon from Department of Energy Facilities,” where the requirements for identifying National Emission Standards for Hazardous Air Pollutants (NESHAP) receptor locations are outlined. Receptor locations (residences, schools, businesses, or farm operations) were identified using high-resolution satellite imagery. This assessment identified 31 unique receptor locations for all INL Site facilities, and 30 receptor locations for INL in-town facilities that have the potential to emit radioactive materials. Identification of receptors for each in-town facility is new to this report.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

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.

61 RADIATION PROTECTION AND DOSIMETRY↗