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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↗

Evaluation of Naturally Occurring Be-7 Activity on LANL Stack Filter Clumps

Los Alamos National Laboratory (LANL) is responsible for providing solutions to challenging issues through multidisciplinary science, engineering, and technology that impact national security. As part of the Radioactive Air Emissions Management (RAEM) Team, it is our responsibility to ensure LANL operates within the requirements of the Code of Federal Regulations 40 CFR 61, Subpart H, National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities (Rad-NESHAP). The standard states, “Emissions of radionuclides to the ambient air from Department of Energy facilities shall not exceed those amounts that would cause any member of the public to receive in any year an effective dose equivalent of 10 mrem/yr” (EPA, 2002) During a routine assessment of LANL’s Rad-NESHAP compliance program, an opportunity for improvement was identified that addresses the evaluation of routine stack samples which potentially have naturally occurring radioactive materials (NORM) on the filter media. In the past and based on professional judgment, detections of NORM such as K-40 and Be-7 typically were rejected from the analytical results. The assessment finding suggested developing a technical criterion to ensure that such rejections were justified, comparing actual measured values with anticipated NORM concentrations for various stacks located at LANL. The significance of accepting or rejecting samples as “true” or “NORM” and its impact on the RAEM’s mission and compliance to the regulations is explained later in the document. Additionally, this document will describe the process and calculations for how such results are to be accepted as actual samples “true positive” or rejected as NORM.

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL P↗

Evaluating Precision of Measured Radionuclide Ambient Air Concentrations

According to AIRNET – Quality Assurance Project Plan for the Radiological Air Sampling Network, SOP-5140, Revision 2 (to become EPC-CP-PIP-5140): “The regulation 40 CFR Part 61.93 requires that the system be able to readily detect a dose of 1.0 mrem above background. Following statistical principles and assuming 95% confidence for such a measurement, we require that 95% of all measurements must fall within two standard deviations of the mean. This represents the minimum acceptable precision for decision making.” An independent assessment of the Rad-NESHAP program completed in early 2019 found that no documentation existed proving that the Airnet data meets the precision defined above. Therefore, to address this particular finding, Airnet concentration data was pulled from the Environmental Information Management (EIM), a cloud-based database maintained by Locus Technologies, for analysis.

54 ENVIRONMENTAL SCIENCES↗

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↗

Evaluation of Significance Tests on Stack Sample Data

In October 2023, external assessors visiting LANL’s Rad-NESHAP team reviewed the annual source term documentation package for stack emissions. This document discusses how the team uses significance tests to determine whether or not a measurement represents an actual detection of emitted radioactive material. The significance tests used in the evaluation compare the measured sample result to the Minimum Detectable Activity (MDA) for the sample; to the uncertainty of that measurement; and to the mean blank sample for the same time period. The blank test uses the average blank plus 2-standard deviations (2σ) of the blank results as a comparison threshold for this final evaluation.

54 ENVIRONMENTAL SCIENCES↗

Flange Tritium Waste Containers Operational Concerns: How to Address the Issues Through the Venting Design

As a part of the U.S. Department of Energy (DOE), Los Alamos National Laboratory (LANL or Laboratory) must comply with regulations in the Clean Air Act (CAA) put forth in 40 Code of Federal Regulations (CFR) 61, Subpart H “National Emission Standards for Emissions of Radionuclides Other Than Radon from Department of Energy Facilities.” The standard states, “Emissions of radionuclides to the ambient air from Department of Energy facilities shall not exceed those amounts that would cause any member of the public to receive in any year an effective dose equivalent of 10 mrem/yr [millirem per year] [1].” This regulation is referred to as the National Emission Standards for Hazardous Air Pollutants for Radionuclides (Radionuclide NESHAP or Rad-NESHAP).

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

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.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

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).

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

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.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

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↗

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.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

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↗

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↗

Comparison of Projections for a Short-Term Release, CAP88 vs NARAC

The purpose of this study was to compare the projected dose using different plume models, evaluating a short duration release of tritium to the 16 compliance sectors and 4 additional points of interest using local meteorology. This report is written as guidance to the decision makers when reviewing this specific Gaussian plume model intended for radiological dose assessment and regulatory compliance, called CAP88 1 , as compared to a more-complex model designed for emergency response. The emergency response model, NARAC 2 , can be used to supplement the CAP88 compliance model evaluations, since NARAC is intended for use in situations where releases are shorter in duration and have increased complexity in terrain and meteorology.

54 ENVIRONMENTAL SCIENCES↗

TA-54 Flanged Tritium Waste Container Operations, Radioactive Air Emissions Summary Volume 1: Stack Emissions & Off-Site Dose Consequence

In September 2025, pressure mitigation operations began on the four Flanged Tritium Waste Containers (FTWCs) that had been in storage at Los Alamos National Laboratory (LANL), Technical Area (TA-) 54, Area G, Building 1028. Each FTWC was opened at TA-54 and put into a stable configuration, then containers were moved to LANL’s Weapons Engineering Tritium Facility (WETF) for further processing in preparation for shipment off-site. Over the course of 13 operational days, the project had air emissions of 123 curies of tritium (hydrogen-3). The radiological dose to the hypothetical maximally exposed individual (MEI) member of the public from these emissions was 0.012 millirem. This is well within the limits established by the Environmental Protection Agency (EPA), which allows 10 millirem per year to any member of the public. Naturally occurring background radiation in Northern New Mexico averages about 300-400 millirem per year to residents. This report is intended to briefly summarize operations that took place in September and October 2025, provide documentation of the radionuclide air emissions from these operations, and summarize the off-site dose consequence to the public that resulted from these air emissions. Informal notifications addressing these areas were made via email to the EPA and NMED throughout the project, and summaries of these data were also posted on the LANL external web site 1 for FTWC operations.

54 ENVIRONMENTAL SCIENCES↗