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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 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

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

PNNL-Richland Campus Radionuclide Air Emissions Report for Calendar Year 2024

This report documents radionuclide air emissions that result in the 2024 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The total dose to the MEI from all PNNL-Richland campus radionuclide emissions in 2024, including fugitive emissions and radon, is 1.3E-05 mrem (1.3E-07 mSv) EDE, or 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland campus is in compliance. The dose attributable to radon emissions is 4.1E-10 mrem (4.1E-12 mSv) EDE.

40 CFR 61 Subpart H

PNNL Richland Campus Radionuclide Air Emissions Report for Calendar Year 2025

This report documents radionuclide air emissions that result in the 2025 highest effective dose equivalent (EDE) to an offsite member of the public, referred to as the maximally exposed individual (MEI). The report has been prepared in compliance with the Code of Federal Regulations, Title 40, Protection of the Environment, Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities” and Washington Administrative Code Chapter 246-247, “Radiation Protection–Air Emissions.” The total dose to the MEI from all PNNL Richland Campus radionuclide emissions in 2025, including fugitive emissions and radon, is 1.8E-05 mrem (1.8E-07 mSv) EDE, or more than 100,000 times less than the federal and state standard of 10 mrem/yr, with which the PNNL Richland Campus is in compliance. The dose attributable to radon emissions is 1.5E-13 mrem (1.5E-15 mSv) EDE.

40 CFR 61 Subpart H

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

EMP, Attachment 1: Sampling and Analysis Plan (Rev.1)

This Sampling and Analysis Plan (SAP) is written for the Environmental Radiation Task activities related to radioactive air emissions (stack) monitoring and environmental radiological ambient air surveillance of Pacific Northwest National Laboratory (PNNL) operations at the PNNL-Richland campus and PNNL-Sequim campus. PNNL is a U.S. Department of Energy Office of Science laboratory in Richland, Washington. This plan is an attachment to PNNL’s Environmental Radiological Air Monitoring Plan (EMP) (PNNL-20919) and addresses a discrete, vital subject area that is subject to revision independent of the main text of the EMP document. This SAP provides the requirements for planning sampling events and the requirements imposed on the services provided by the analytical laboratory to the PNNL Environmental Radiation Task.

40 CFR 61 Subpart H

EMP - Environmental Radiological Air Monitoring Plan: PNNL Operations in Washington

The Environmental Radiological Air Monitoring Plan (EMP) for Pacific Northwest National Laboratory (PNNL) describes systems/processes/practices related to radiological operations in Richland and Sequim, Washington, that are associated with environmental radiological air monitoring and surveillance activities. The activities described support the lab’s responsibility to maintain safe operations and minimize negative impacts to both onsite and offsite persons and environment. Dose assessments required by regulations and DOE Orders for the public and biota are described. PNNL conducts environmental air surveillance monitoring as part of the PNNL Site Radioactive Air Emissions License (RAEL)-005 for Richland Campus, issued in 2010 with its most recent renewal effective in January 2021. The radioactive air emissions license for the PNNL-Sequim campus (RAEL-014) was issued to the U.S. Department of Energy in 2012 with its most recent renewal effective in January 2023. The EMP is a compilation of the following four documents: - Environmental Radiological Air Monitoring Plan (this main document) (PNNL-20919) - Sampling and Analysis Plan (Attachment 1) (PNNL-20919-1) - Data Management Plan (Attachment 2) (PNNL-20919-2) - Dose Assessment Guidance (Attachment 3) (PNNL-20919-3).

40 CFR 61 Subpart H

PNNL Dose-per-Unit-Release Factors for Calculating Radionuclide Emissions Potential-to-Emit Doses

Revised PNNL-Richland campus dose-per-unit release factors based on the Environmental Protection Agency code CAP88-PC Version 4.1.1 code are provided. In addition to maximum receptor dose factors, maximum air concentration dose factors are provided. The PNNL-Sequim campus dose-per-unit release factors are included, as well, based on the Environmental Protection Agency code COMPLY Version 1.7.1.

40 CFR 61 Subpart H

Summary of Analytical Services for the Hanford Site Radionuclide NESHAP Program

This document is a summary of the point source analytical requirements used to demonstrate compliance for the Department of Energy (DOE) Hanford Site operations with 40 Code of Federal Regulations (CFR) Part 61, “National Emission Standards for Hazardous Air Pollutants,” (NESHAP) Subpart H, “National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities,” and the Washington Administrative Code (WAC) 246-247, “Radiation Protection – Air Emissions.” This reference collects information from multiple source documents and is not intended to create, supersede, replace or over-ride any existing contractual, DOE, federal or state statutes, regulations, compliance agreements, orders, permits, licenses or other requirements. The requirement source document governs where any difference may exist. The Hanford Mission Integration Solutions (HMIS) Environmental organization has been contracted by DOE to manage and report data collected from the sampling and monitoring of radioactive air emissions point sources, colloquially called stacks. The Environmental organization coordinates the analyses and reporting of samples collected at various facilities across the Hanford Site. These facilities operate approximately 52 stacks that require sampling, monitoring or estimating radioactive air emissions. The stacks are operated by Bechtel National, Inc. (BNI), Central Plateau Cleanup Company (CPCCo), Hanford Tank Waste Operations & Closure (H2C), Hanford Laboratory Management and Integration (HLMI), and Pacific Northwest National Laboratory (PNNL). Stack samples from CPCCo, HLMI and H2C facilities are collected by the operating contractor staff, delivered to HMIS, and then shipped to an offsite contracted laboratory for analyses. The field and laboratory sample data uploaded into the Sample Management and Analytical Results Tracking (SMART) database are used to calculate sample volumes and concentrations. Sample concentrations are evaluated for compliance with federal and state regulations, permits, and license requirements. The SMART database also calculates total curies released for sampled point sources and stacks. Point source effluent concentrations and releases are published annually in publicly available reports. The BNI and PNNL operate several DOE-Hanford Field Office (HFO) stacks subject to the requirements of 40 CFR 61, Subpart H and WAC 246-247. The concentrations, curies released and dose modeling evaluation for these stacks are included in the DOE-HFO annual radionuclide NESHAP report. The sample collection, analyses and emissions estimates for these stacks are outside the scope of HMIS contracted responsibilities and not addressed further in this document.

54 ENVIRONMENTAL SCIENCES

PNNL Sequim Campus Radionuclide Air Emissions Report for Calendar Year 2025 : Department of Energy – Office of Science Pacific Northwest National Laboratory

The U.S. Department of Energy Office of Science’s Pacific Northwest Site Office has oversight and stewardship duties associated with the Pacific Northwest National Laboratory Sequim Campus. Facility operations include radiological operations with the potential-to-emit low levels of radioactive materials. This report is prepared to document compliance with the 40 CFR Part 61, National Emission Standards for Hazardous Air Pollutants, Subpart H, “National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities,” and Washington Administrative Code Chapter 246-247, Radiation Protection–Air Emissions. The PNNL Sequim Campus is in compliance with the federal and state 10 mrem/yr standard for 2025 operations.

40 CFR 61 Subpart H