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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↗

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↗

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↗

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↗

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↗

Updated Application of Frequency of Detection Methods for the INL Site Ambient Air Monitoring Network

This report presents a quantitative assessment of the current INL Site air monitoring network using frequency of detection (FD) methods. The first assessment of the INL network was performed in 2015 and made recommendations for improving the network. As a result of changes made in response to the recommendations and the addition of new source locations, the network was modified and reassessed in 2017. Since 2017, administration of the air sampling program has been consolidated under one contractor, which resulted in additional changes to the network (sampler numbers and locations) and changes in radionuclide detection levels. As a result of these changes and others, an updated assessment of the INL Site ambient air monitoring network was performed. The same two exposure scenarios used in previous assessments were used for this assessment: a resident scenario and a shepherd/rancher scenario. The resident was assumed to be continuously present at their residence/business/farm operation outside the INL Site boundary while the shepherd/rancher was assumed to be present 24-hours at the nearest INL grazing allotment boundary in each of the 22.5-degree sectors along the sector centerline from each source. Updates to both the resident and shepherd/rancher receptor locations were included. Other changes include updates to flow rates for stack sources, expansion of the list of important radionuclides based on the most recent National Emission Standards for Hazardous Pollutants (NESHAPs) analysis, and updated dose coefficients. The assessment was conducted to determine whether the current INL monitoring network is capable of detecting releases of important radionuclides from INL Site sources that have the potential to exceed a conservative dose threshold for the two exposure scenarios. The assessment revealed that for the resident scenario, the current network meets the desired performance objective (FD = 95%) for all radionuclides and sources except for Cl-36 from the TRA-770 stack (94.4%). For the shepherd/rancher scenario, the FD performance objective is met for all radionuclides and sources except tritium from MFC-774 and TAN 679 (91% for both). An investigation of reported emissions for the past three years revealed that Cl 36 is not emitted from TRA-770, and routine tritium emissions from MFC-774 and TAN-679 are very small and the sources are likely incapable of emitting enough tritium to cause a release that should be detectable by the monitoring network. This assessment is based on a conservative dose threshold. This coupled with fact that the FD for Cl 36 is only slightly less than the performance objective and Cl-36 is not emitted from TRA-770, modifying the network (i.e. adding another sampler, increasing sampler flow rate, moving samplers) to meet the 95% performance objective for this radionuclide/source/receptor scenario is not warranted. Similarly, because tritium emissions from MFC-774 and TAN-679 are very small and these two sources are likely incapable of causing a dose due to tritium release that should be detectable by the network, modifications to increase tritium detection for these sources is also unwarranted at this time. However, if it is required to meet the performance objective for tritium for all sources and receptor scenarios, additional analysis determined the FD could be raised from 91% to > 99% for both sources by adding two tritium samplers to the network.

61 RADIATION PROTECTION AND DOSIMETRY↗

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↗

Pacific Northwest National Laboratory Facility Radionuclide Emission Points and Sampling Systems

Battelle–Pacific Northwest Division operates numerous research and development laboratories in Washington State. The U.S. Department of Energy (DOE) contracts to Battelle at Richland facilities on both the DOE Hanford Site and the Pacific Northwest National Laboratory (PNNL) Richland campus. These facilities have the potential for radionuclide air emissions. The PNNL contract with DOE also includes operations at the PNNL-Sequim campus in Sequim, where there is also the potential for radionuclide air emissions. This document is a periodic update that describes current PNNL facility emission units and sampling systems. The National Emission Standard for Hazardous Air Pollutants (NESHAP [40 Code of Federal Regulations 61, Subpart H]) requires an assessment of all emission units that have the potential for radionuclide air emissions. Emission units are registered with the State of Washington. Potential emissions from emission units are assessed annually by PNNL staff. Sampling, monitoring, and other regulatory compliance requirements are designated based on the potential to-emit dose criteria, a graded approach to facility-identified potential impact categories, and regulatory requirements. The purpose of this document is to describe the facility radionuclide air emission sampling program and provide current and historical facility emission unit system performance, operation, and design information. For sampled emission units, the building, exhaust unit, control technologies, and sample extraction details are provided. Additionally, applicable configuration drawings, figures, and photographs are included. For non-sampled emission units, emission estimation and radionuclide source details are provided. Site-wide permits for the lowest potential impact category are described. Deregistered/transitioned emission unit details are also provided as necessary for at least 5 years post-closure/transition. Currently, five emission units are sampled continuously for particulate radionuclides at PNNL managed facilities on the PNNL-Richland campus (3 of the 5) and on the Hanford Site (2 of the 5). Four of these units have sampling systems that comply with the American National Standards Institute/Health Physics Society (ANSI/HPS) N13.1–2011 standard for sampling from stacks and ducts of nuclear facilities, and the fifth is grandfathered and compliant with the older ANSI N13.1–1969 standard. In addition, the PNNL-managed Hanford Site 325 Building EP 325-01-S stack is sampled continuously for emissions of tritium. No emissions sampling is required for the single licensed emission unit on the PNNL-Sequim campus.

54 ENVIRONMENTAL SCIENCES↗

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; 40 CFR Part 61, Subpart H) and State requirements in Washington Administrative Code 246–247 and 173-480 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, which formerly was known as the Marine Sciences Laboratory). This report describes the inventory-based methods and provides the results for the NESHAP assessment performed in January 2021 for calendar year ending 2020.

40 CFR 61 Subpart H↗

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↗

Calculating Potential Radiological Emissions for Waste Management Activities at INL - 20068

At Idaho National Laboratory (INL), work involving radionuclides is evaluated for potential emissions from a project in order to comply with the National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations, 40 CFR 61 Subpart H. Emission calculations are documented in an Air Permitting Applicability Determination (APAD) to analyze unmitigated and mitigated emissions and determine if an Application to Construct (ATC) or continuous monitoring is required. To calculate the unmitigated and mitigated emissions, a spreadsheet was developed to provide ease in determining potential emissions by providing the maximum operating temperature and the material being used. The spreadsheet aids in determining the potential emissions for research projects and waste management activities at Materials and Fuels Complex (MFC) and other locations across the INL site. Furthermore, it can also be used for periodic confirmatory measurements (PCM) to justify low emissions. Elements that factor into the unmitigated and mitigated calculations include the amount of each radionuclide used (in curies or grams), specific activity (if amount is given in grams), the temperature the material is heated to in Celsius, the dose conversion factor which is derived from Clean Air Act Assessment Package - 1988 (CAP-88) modeling, and the number of HEPA filters used for mitigated measures. The main drivers for calculating the unmitigated emissions for a project are the amount used per radionuclide, the maximum operating temperature, and the location of the work. The maximum operating temperature determines the airborne release factor which is dependent on the physical state of the radionuclide. Prior to October 2017, if the radionuclide was heated to greater than 100 deg. C, the radionuclide was assumed to be a gas, which has the highest airborne release factor. This assumption would be overly conservative for radionuclides with high melting and boiling points, which provided a challenge to demonstrate low emissions. In October 2017, the Environmental Protection Agency (EPA) approved an alternative method for INL. This method allows the airborne release factor to be determined by using the melting point and 90% of the boiling point of the radionuclide. This methodology was included in the spreadsheet to allow unmitigated emission calculations for APADs to be completed more efficiently and effectively. Results show a reduction in time completing air emission calculations as well as lower total emissions across all facilities at INL. MFC annual emissions were reduced by 62% from the previous year and Research and Education Campus (REC) facilities were reduced by 38% due to implementation of the approved alternative method. Time spent on APADs, PCMs, and documentation for the annual NESHAP report was also reduced significantly. The spreadsheet provided in Table I provides the potential emission calculations for the 'Advanced Retrieval and Disposition Techniques for Remote Handled Mixed Low Level Waste (RH MLLW) at the Radioactive Scrap and Waste Facility (RSWF)' project. Calculations show the Potential Effective Dose Equivalent (PEDE) at RSWF to be 7.27 E-04 mrem/yr (7.27 E-09 Sv/yr) which is well below the 0.1 mrem/yr threshold. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Pacific Northwest National Laboratory Facility Radionuclide Emission Points and Sampling Systems

Battelle–Pacific Northwest Division operates numerous research and development laboratories in Richland, Washington. U.S. Department of Energy (DOE) contracts to Battelle include Richland facilities on the DOE Hanford Site and the Pacific Northwest National Laboratory (PNNL) – Richland Campus that have the potential for radionuclide air emissions. The PNNL contract also includes DOE operations at the PNNL-Sequim Campus, in Sequim, Washington, where there is also the potential for radionuclide air emissions. This document is a periodic update that describes current PNNL facility emission units and sampling systems.

54 ENVIRONMENTAL SCIENCES↗

Pacific Northwest National Laboratory Facility Radionuclide Emission Points and Sampling Systems

Battelle–Pacific Northwest Division operates numerous research and development laboratories in Washington State. The U.S. Department of Energy (DOE) contracts to Battelle at Richland facilities on both the DOE Hanford Site and the Pacific Northwest National Laboratory (PNNL)-Richland campus. These facilities have the potential for radionuclide air emissions. The PNNL contract with DOE also includes operations at the PNNL-Sequim campus in Sequim, where there is also the potential for radionuclide air emissions. This document is a periodic update that describes current PNNL facility emission units and sampling systems.

54 ENVIRONMENTAL SCIENCES↗

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.

61 RADIATION PROTECTION AND DOSIMETRY↗