National Emission Standards for Hazardous Air Pollutants – Radionuclide Emissions Calendar Year 2017
Report submitted to regulators (State of Nevada and EPA Region IV). Required to document compliance with 40 CFR 61 Subpart H. The U.S. Department of Energy, 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. The release of radionuclides from NNSS activities has 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 nuclear testing ended in 1992, radiation monitoring focused on detecting airborne radionuclides from historically contaminated soils. 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 man-made radiation, the Clean Air Act, National Emission Standards for Hazardous Air Pollutants (NESHAP) (Title 40 Code of Federal Regulations [CFR] Part 61 Subpart H) (CFR 2010a) limits the release of radioactivity from a U.S. Department of Energy (DOE) facility to that which would cause 10 millirem per year (mrem/y) effective dose equivalent 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 using environmental measurements of radionuclide air concentrations at critical receptor locations on the NNSS (U.S. Environmental Protection Agency [EPA] and DOE 1995). This method was approved by the 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 actually pseudo-critical receptor stations because no member of the public resides at these onsite locations. Compliance is demonstrated if the measured annual average concentration is less than the NESHAP Concentration Level (CL) for Environmental Compliance listed in 40 CFR 61, Appendix E, Table 2 (CFR 2010a). 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. In 2017, 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 air sampling data collected at the critical receptor air monitoring stations which had average concentrations of radioactivity that were a fraction of the CL values. Concentrations ranged from 0.2% to a maximum of 5.7% of the allowed NESHAP limit. Clean Air Package 1988 (CAP88) was used to model dose to the offsite public from all 2017 NNSS radionuclide emissions. The model showed the maximally exposed individual to be on the adjacent U.S. Air Force Nevada Test and Training Range; this individual received a dose of 0.07 mrem/y. The potential dose to the public from NLVF emissions was also very low at 0.0000098 mrem/y, over six orders of magnitude lower than the 10 mrem/y limit.