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NUTRON NESHAPs Dashboard

My project aims to enhance the Nuclear Material Tracking Application (NUTRON) software by integrating a tool for the National Emission Standards for Hazardous Air Pollutants (NESHAP) emissions calculations and presenting this data on a dashboard. Inefficiencies in the current NESHAP calculation process were addressed, which will result in more timely regulatory compliance efforts. Key improvements include revising the transfer request system, incorporating effective dose calculations, and developing a data visualization dashboard into NUTRON. The project involved creating a wireframe, preparing an Engineering Calculations and Analysis Report (ECAR), stakeholder meetings, and providing supplemental documentation. Key findings indicate that the proposed modifications will streamline the NESHAP calculation process, reduce human error, and provide REC personnel with accurate and timely data for material use determinations and dose estimations. Future work focuses on completing the NUTRON modifications and fully integrating the new features, ensuring a more efficient and reliable system for tracking and reporting nuclear material transfers.

99 - GENERAL AND MISCELLANEOUS↗

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 ↗

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↗

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↗

Summary of Analytical Services for the Hanford Site Radionuclide NESHAP Program

This document serves as a summary of the analytical requirements used to demonstrate compliance on the Department of Energy (DOE) Hanford Site to 40 CFR 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 WAC 246-247, “Radiation Protection – Air Emissions.” This document is a reference summarizing information from multiple existing requirement source documents and does not create, supersede, replace or over-ride any existing contractual, DOE, federal, state, permit or license requirement. The requirement source documents govern where any differences may exist.

54 ENVIRONMENTAL SCIENCES↗

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↗

Annual Performance Testing of Tracer Gas Detectors for use in Radionuclide NESHAP Compliance Testing

Los Alamos National Laboratory’s (LANL’s) compliance with Radionuclide NESHAP0F 1 regulations is managed by the Radioactive 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. Prior to commissioning a new stack sampling system, the ANSI Standard for stack sampling requires that the stack sample location must meet several criteria, including uniform mixing of tracer gas (sulfur hexafluoride, SF 6 ) and tracer aerosol (liquid oil droplets) in the air stream. This memorandum will specifically focus on the tracer gas portion of the ANSI Standard. For these mix tests, tracer gas is injected into the stack air stream and the resulting air concentrations are measured across the plane of the stack at the proposed sampling location. The coefficient of variation of the media concentration must be under 20% when evaluated over the central 2/3 area of the stack or duct.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Documentation of Air Emissions Source Term for Radionuclide NESHAP Compliance: TA-53 Building 0984 Isotope Production Facility

This paper will document the air emissions source term for the TA-53 Building 0984 Isotope Production Facility (IPF). The facility has historically been managed as a minor source under Radionuclide NESHAP regulations, but began using a wider variety of irradiation targets and a higher beam current. To support expanded generation of actinium-225 for medical diagnostic and therapeutic uses, IPF is now irradiating thorium targets and the beam current is planned to increase from 250 microamperes up to 600 microamperes. These changes merit a review of the anticipated source term under the new proposed operational conditions. The end result of the review indicates the main stack (Exhaust Stack ES-1) needs to be managed as a major source with continuous emissions monitoring. No additional advance notifications or permitting is required as a result of these operational changes.

54 ENVIRONMENTAL SCIENCES↗

National Emission Standards for Hazardous Air Pollutants (NESHAP) Memorandum of Agreement (MOA) Between NASA Headquarters and MSFC (Marshall Space Flight Center) for NASA Principal Center for Review of Clean Air Regulations

This paper presents a memorandum of agreement on Clean Air Regulations. NASA headquarters (code JE and code M) has asked MSFC to serve as principle center for review of Clean Air Act (CAA) regulations. The purpose of the principle center is to provide centralized support to NASA headquarters for the management and leadership of NASA's CAA regulation review process and to identify the potential impact of proposed CAA reguations on NASA program hardware and supporting facilities. The materials and processes utilized in the manufacture of NASA's programmatic hardware contain HAPs (Hazardous Air Pollutants), VOCs (Volatile Organic Compounds), and ODC (Ozone Depleting Chemicals). This paper is presented in viewgraph form.

Caruso, Salvadore V.↗

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↗

Joint EPA/NASA/USAF Interagency Depainting Study

Environmental regulations such as National Emission Standards for Hazardous Air Pollutants (NESHAPs) are drivers for the implementation of environmentally compliant methodologies in the manufacture of aerospace hardware. In 1995, the Environmental Protection Agency (EPA) promulgated the NESHAP for the Aerospace Manufacture and Rework (Aerospace NESHAP) industry. Affected facilities were to be in compliance by September 1998. Several aerospace manufacturing operations are regulated within the Aerospace NESHAP including Depainting operations. The National Aeronautics and Space Administration (NASA), EPA, and United States Air Force (USAF) combined resources to evaluate the performance of nine alternative depainting processes. The seven alternative depainting processes were: (1) Chemical stripping (non-methylene chloride); (2) Carbon Dioxide Blasting; (3) Xenon Flashlamp; (4) Carbon Dioxide Laser Stripping; (5) Plastic Media Blasting; (6) Sodium Bicarbonate Wet Stripping; and (7) Waterjet Blasting and Wheat Starch Blasting. All epoxy primer and polyurethane top coat system was applied to 2024-T3 clad and non-clad aluminum test specimens. Approximately 200 test specimens were evaluated in this study. Each coupon was subjected to three, four, or five complete depainting cycles. This paper discusses the conclusions from the study including the test protocol, test parameters, and achievable strip rates for the alternative depainting processes. Test data includes immersion corrosion testing, sandwich corrosion testing and hydrogen embrittlement testing for the non-methylene chloride chemical strippers. Additionally, the cumulative effect of the alternative depainting processes on the metallurgical integrity of the test substrate is addressed with the results from tensile and fatigue evaluations.

Clark-Ingram, M.↗

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 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↗

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↗

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↗

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↗