National Emission Standards for Hazardous Air Pollutants - Radionuclide Emissions, Calendar Year 2011
The U.S. Department of Energy, National Nuclear Security Administration Nevada Site Office operates the Nevada National Security Site (NNSS) and 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. Limitation to underground detonations after 1962 greatly reduced radiation exposure to the public surrounding the NNSS. After nuclear testing ended in 1992, NNSS 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) limits the release of radioactivity from a U.S. Department of Energy (DOE) facility to that which would cause 10 millirem per year (mrem/yr) 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 the damaged Fukushima nuclear power plant in Japan. Radionuclides from the Fukushima nuclear power plant were detected at the NNSS in March 2011 and are discussed further in Section III. The NNSS demonstrates compliance with the NESHAP limit by using environmental measurements of radionuclide air concentrations at critical receptor locations. This method was approved by the EPA for use on the NNSS in 2001 and has been the sole method used 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 actually resides at these onsite locations. Compliance is demonstrated if the measured annual average concentration is less than the NESHAP Concentration Levels (CLs) for Environmental Compliance listed in 40 CFR 61, Appendix E, Table 2. 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 2011, the potential dose from radiological emissions to air, resulting from both current and past NNSS activities, at onsite compliance monitoring stations was well below the 10 mrem/yr dose limit. Air sampling data collected at all air monitoring stations had average concentrations of radioactivity that were a fraction of the CL values. Concentrations ranged from less than 1% to a maximum of 12.2% of the allowed NESHAP limit. Because the nearest member of the public resides about 20 kilometers from potential release points on the NNSS, dose to the public would be only a small fraction of the value measured on the NNSS. The potential dose to the public from NLVF emissions was also very low at 0.000024 mrem/yr, more than 400,000 times lower than the 10 mrem/yr limit.