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All sourcesNASA NTRSDOE OSTI
DOE OSTI2023

Review of New or Modified Radioactive Air Emission Sources

This Environmental Protection and Compliance (EPC), Compliance Programs (CP) Quality Procedure (QP) describes the process for review and evaluation of new and modified sources of radioactive air emissions to determine the requirements for pre-construction approval, stack monitoring, stack sampling system upgrade, ambient air monitoring, and the implementation of As Low As Reasonably Achievable (ALARA) principles. These requirements are specified in 40 CFR 61 Subpart H and by DOE Order 458.1, Radiation Protection of the Public and the Environment.

61 RADIATION PROTECTION AND DOSIMETRY↗
DOE OSTI2023

Methods to Account for CAP-88 PC-Omitted Nuclides in Radioactive Air Emissions From DOE Facilities

Routine research and development activities at US Department of Energy facilities can result in the release of radioactive emissions, potentially exposing the public and the environment. Such emissions are subject to certain Clean Air Act regulations, specifically those outlined in 40 CFR Part 61, Subpart H, which are enforced by the US Environmental Protection Agency. Compliance is determined in part with a dose standard. Doses to members of the public from most US Department of Energy facility airborne emissions are modeled using CAP-88 PC software, the latest version of which contains more than 1,200 radionuclides. Radioactive effluents from US Department of Energy facilities may contain radioisotopes that are not available in CAP-88 PC, and those radioisotopes must still be evaluated to determine whether doses to members of the public are below established limits. CAP-88 PC-omitted radionuclides can be accounted for using alternate methods, including the use of surrogate radionuclides. Here, this paper elucidates the process of accounting for CAP-88 PC-omitted radionuclides by providing criteria and rationale for surrogate selection, a compilation of surrogate radionuclides used in the past by US Department of Energy facilities, a discussion of alternate methods used to account for CAP-88 PC-omitted radionuclides and a comparison of methods and impacts on receptor doses. Ultimately, this paper aims to aid in the process of surrogate selection and consequently to simplify and expedite compliance with Clean Air Act regulations.

61 RADIATION PROTECTION AND DOSIMETRY↗
DOE OSTI2022

Meta-Study of Particulate Detection Losses on Radioactive Air Sample Filters

Several mathematical relationships between air sample filter mass loading and the correlated analytical self-absorption factor were developed using data from other published research in this meta-study. Gross-alpha and -beta applications are addressed for this research. As filter media becomes loaded with particulate matter, there is potential for measurement losses due to self-absorption by mass loading. Components contributing to absorption include particulate dust, radioactive particulates, and filter material. Standards indicate a correction factor should be used when the penetration of radioactive material into the collection media or self-absorption of radiation by the material collected would reduce the detection rate by more than 5%. Previously, losses due to self-absorption have been reported up to 100% over a range up to ~10 mg∙cm -2 mass loading. These absorption losses then can be used to determine a correction factor for sample results. For low mass loadings (e.g., ≤0.1 mg∙cm -2 ) corrections factors in the 0.85 - 1 range have been recommended and used, while at higher mass loadings nearer to 10 mg∙cm -2 correction factors closer to 0 (representing near 100% losses) are used. Based on data from published studies, the different methods for relating percent loss due to self-absorption to mass loading include linear, exponential, quadratic, and trinomial derived functions. Where applicable, both forced zero and non-forced zero results were evaluated. From the derived functions evaluated, the trinomial function provided the best fit. Once the sample filter mass loading is known, the trinomial function can be applied to estimate losses and the corresponding self-absorption factor. When applied to routine operating conditions for radiological facility stacks monitored at the Pacific Northwest National Laboratory for an average sample filter mass loading of 0.09 ± 0.12 (2σ) mg∙cm -2 (excluding negative values and outliers) and a range from 0 - 0.24 mg∙cm -2 , the estimated trinomial function nominal self-absorption losses are less than 5% at 0.09 mg∙cm -2 and less than 10% at 0.24 mg∙cm -2 . The trinomial function is one method that may be used to adjust the activity results of an air sample when the sample-specific mass loading is determined. The application of no correction factor when the ANSI/HPS N13.1-2021 guidance of a 5% threshold for loss is not reached with typical stack sample mass loadings may be reasonable in high-efficiency particulate air filtered systems. For simplicity, it would be conservative in assigning the self-absorption correction factor at the 5% threshold (i.e., 0.95) for general uses but in cases of heavy mass loading to calculate the factor.

air sampling↗
DOE OSTI2025

TA-54 Flanged Tritium Waste Container Operations, Radioactive Air Emissions Summary Volume 1: Stack Emissions & Off-Site Dose Consequence

In September 2025, pressure mitigation operations began on the four Flanged Tritium Waste Containers (FTWCs) that had been in storage at Los Alamos National Laboratory (LANL), Technical Area (TA-) 54, Area G, Building 1028. Each FTWC was opened at TA-54 and put into a stable configuration, then containers were moved to LANL’s Weapons Engineering Tritium Facility (WETF) for further processing in preparation for shipment off-site. Over the course of 13 operational days, the project had air emissions of 123 curies of tritium (hydrogen-3). The radiological dose to the hypothetical maximally exposed individual (MEI) member of the public from these emissions was 0.012 millirem. This is well within the limits established by the Environmental Protection Agency (EPA), which allows 10 millirem per year to any member of the public. Naturally occurring background radiation in Northern New Mexico averages about 300-400 millirem per year to residents. This report is intended to briefly summarize operations that took place in September and October 2025, provide documentation of the radionuclide air emissions from these operations, and summarize the off-site dose consequence to the public that resulted from these air emissions. Informal notifications addressing these areas were made via email to the EPA and NMED throughout the project, and summaries of these data were also posted on the LANL external web site 1 for FTWC operations.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2025

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↗
DOE OSTI2024

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↗
DOE OSTI2025

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↗
DOE OSTI2024

EMP, Attachment 2: Data Management Plan

This Data Management Plan (DMP) is an attachment to the Pacific Northwest National Laboratory Environmental Radiological Air Monitoring Plan (EMP). PNNL is a U.S. Department of Energy Office of Science national laboratory. Radioactive effluent monitoring and environmental surveillance for PNNL operations in Washington State are the responsibility of the PNNL Environmental Protection and Regulatory Programs division and are conducted by the Environmental Radiation Task staff. This DMP describes the data management processes for PNNL radioactive air emissions (stack) monitoring and environmental radiological ambient air surveillance activities.

40 CFR 61 Subpart H↗
DOE OSTI2024

Data Quality Objectives Supporting Radiological Air Emissions Monitoring for the PNNL-Richland Campus: North Campus Construction (Rev. 3)

Starting in fiscal year 2023, the north area of the PNNL-Richland Campus will undergo development. Initially, infrastructure (water, electrical) improvements will be installed. Later development includes the construction of several new office buildings. The area to be developed currently contains no buildings but does have two existing solar-powered ambient air sampling stations. Under the requirements of Washington State Department of Health Radioactive Air Emissions License -005, the PNNL-Richland Campus must operate and maintain a radiological air monitoring program. This revision documents and evaluates how the new North Campus construction impacts ambient air surveillance stations within the development region. This revision also considers current stack configurations and uses an updated environmental dispersion model and updated meteorological data. The DQO team concluded that one sampling station in the construction area will be relocated and the other remain in place. The evaluations conducted for this DQO also identified a third sampling station outside the development area that is recommended for relocation as a result of updated dispersion modeling. Recommended sites for the relocations are presented. Considerations for sampling in and around a construction zone are also addressed. Additionally, programmatic improvements to the ambient air sampling program were identified in the DQO process.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2023

Environmental Air Monitoring at LANL: 2023 External Program Assessment [Slides]

Radioactive Air Emissions Management evaluates radiological impacts of LANL operations on members of the public, identifies and quantifies releases, and assesses impacts. It is not directly affiliated with cleanup operations or programmatic work and has independent oversight. The focus areas in Environmental Compliance Programs are stack emissions measurements, ambient air measurements, minor source operations evaluations, data management and quality assurance, collaboration with Meteorology program, and collaboration with Dose Assessment program (EPC-ES).

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2023

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↗
DOE OSTI2024

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↗
DOE OSTI2020

NESHAPs CY19 Report: Radionuclide Air Emission Report for 2019

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 4.0.1.17, to calculate the dose to the maximally exposed individual member of the public for the Livermore Site and Site 300. In 2019, LLNL maintained its compliance with 40 CFR 61, Subpart H. All radioactive air emissions resulted in calculated doses far below the annual 10 mrem (100 μSv) sitewide standard. The annual doses to the site-wide maximally exposed individual member of the public at the Livermore Site and Site 300 from planned and unplanned operations in 2019 are: Livermore Site: 4.3 x 10⁻³ mrem (4.3 x 10⁻² μSv); Site 300: 9.5 x 10⁻⁸ mrem (9.5 x 10⁻⁷ μSv).

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗
DOE OSTI2024

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 ↗
DOE OSTI2024

Stack Test Summary for TA-59-0001

The Radioactive Air Emissions Management (RAEM) team performed stack flow characterization tests at Technical Area (TA) 59 Building 0001 Exhaust Stack (ES) 8. These tests were completed in accordance with Title 40 of the Code of Federal Regulations (CFR), Part 61, Subpart H and the American National Standards Institute (ANSI) N13.1-1999 required by the Clean Air Act. Subpart H of the regulation is the National Emission Standards for Hazardous Air Pollutants (NESHAP) for radionuclides, which compliance with is maintained by the REAM team.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2023

National Emission Standards for Hazardous Air Pollutants – Radionuclide Emissions Calendar Year 2022

This compliance report is required under 40 CFR 61, Subpart H. It will be submitted by NFO to regulators under NFO Manager signature. STIP needs to be coordinated with NFO review. Previous reports had Kathryn Gladden as the POC for this. While Kathryn should still be on the list of NFO reviewers, Cesar Alfaro (cesar.alfaro@nnsa.doe.gov, 5-4082) is now the NFO POC.

54 ENVIRONMENTAL SCIENCES↗