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DOE OSTI2021

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 ↗
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 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

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↗
DOE OSTI2022

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↗
DOE OSTI2020

2019 LANL Radionuclide Air Emissions Report

In June 2020, Los Alamos National Laboratory (LANL) submitted letter ESHQSS: 20-025 to Region 6 of the Unites States Environmental Protection Agency (EPA). This letter transmitted the 2019 LANL Radionuclide Air Emissions Report to the EPA. This report summarizes LANL operations, air emissions of radionuclides, and subsequent off-site dose consequence from these emissions for calendar year 2019. This report is issued to meet requirements of 40 CFR 61 Subpart H, National Emission Standards for Emissions of Radionuclides other than Radon from Department of Energy Facilities. This regulation, called the Radionuclide NESHAP, establishes a limit of 10 millirem per year to the maximally exposed member of the public and requires an annual report to be submitted to the appropriate EPA Region by June 30th of each year. LANL’s off-site dose from airborne emissions of radionuclides in 2019 was 0.43 millirem. The normal practice is to issue this report directly to EPA Region 6 in June of each year, and then after the report is accepted by the EPA, re-issue the report for inclusion in the LANL Electronic Public Reading Room (EPRR). This second part is usually done in July of each year, but this step was overlooked in July 2020 due to other commitments. We regret this error. This omission was noted in late 2020; we are submitting the 2019 LANL Radionuclide Air Emissions Report to the EPRR now in December 2020. Aside from the addition of this cover sheet explaining the delay, the report is unchanged from the version submitted to EPA Region 6 in June.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2024

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↗
DOE OSTI2023

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↗
DOE OSTI2023

2021 Radionuclide Air Emissions Report for Los Alamos National Laboratory, Revised October 2022

Provided is a revision to the Calendar Year 2021 Radionuclide Air Emissions Report for the Los Alamos National Laboratory (LANL). This report is a regulatory compliance deliverable for LANL under the Radionuclide NESHAP, 40 CFR 61 Subpart H. The revised report is needed to correct an error identified regarding generation of wind data files. These wind data files are used for plume modeling as part of calculating off-sites doses from monitored radionuclide air emissions sources. The error resulted from a software update by LANL’s meteorology team after new towers were added to the tower network. As a result of this error, incorrect wind frequencies were assigned to the different stability classes. This slightly affected the plume model calculations and subsequent off-site dose determinations for analyses using these wind files.

2021 Radionuclide, Air Emissions↗
DOE OSTI2020

Protocol for Determining Actual Flow Rate in FTWC Duct Systems

This paper is intended to document the theory and methods to determine the actual flow rate in the exhaust system used to ventilate the Flanged Tritium Waste Containers based on realtime instrument readings. Section 1 provides introductory and background material; Section 2 details the various correction factors used to adjust flow readings for ambient air pressure and temperature and other operational parameters. Section 3 provides guidance on implementing this process during venting operations, and Section 4 provides supporting documentation and also a field checklist that can be used by personnel during venting. For Revision 1, a summary of editorial changes made to the paper was added as Section 4.4, as well as a section documenting peer review (Section 4.5).

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗
DOE OSTI2022

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↗
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 OSTI2020

Notification of Operational Scope Change for the FTWC Venting Project at Los Alamos National Laboratory (LANL)

This letter is intended to provide you an update on the scope of work for the venting of the Flanged Tritium Waste Containers (FTWCs) at Los Alamos National Laboratory (LANL) Technical Area (TA-) 54. This project was described in the Application for Pre-Construction Approval 1 ("the Application") that was approved by EPA Region 6 on May 22, 2019. As operational planning for this project has been finalized, the scope of work described in the Application has slightly changed. The project has now determined that each FTWC may be vented multiple times, and these venting activities may take place at more than one location. The original application only discussed a single venting operation for each FTWC at a single location, TA-54. However, the radionuclide inventory and expected air releases remain bounded by the values described in the Application.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗
DOE OSTI2021

Notice of Submittal – 2020 Radionuclide Air Emissions Report for Los Alamos National Laboratory

Enclosed is the Calendar Year 2020 Radionuclide Air Emissions Report for the Los Alamos National Laboratory (LANL). The submittal is in compliance with 40 CFR 61 Subpart H. The highest effective dose equivalent to any member of the public from LANL operations in 2020 is 0.29 millirem. This maximally exposed individual location is a business at 132 DP Road, Los Alamos, NM. The annual dose is well below the EPA standard of 10 millirem per year as established in Subpart H.

54 ENVIRONMENTAL SCIENCES↗
DOE OSTI2020

Evaluating Precision of Measured Radionuclide Ambient Air Concentrations

According to AIRNET – Quality Assurance Project Plan for the Radiological Air Sampling Network, SOP-5140, Revision 2 (to become EPC-CP-PIP-5140): “The regulation 40 CFR Part 61.93 requires that the system be able to readily detect a dose of 1.0 mrem above background. Following statistical principles and assuming 95% confidence for such a measurement, we require that 95% of all measurements must fall within two standard deviations of the mean. This represents the minimum acceptable precision for decision making.” An independent assessment of the Rad-NESHAP program completed in early 2019 found that no documentation existed proving that the Airnet data meets the precision defined above. Therefore, to address this particular finding, Airnet concentration data was pulled from the Environmental Information Management (EIM), a cloud-based database maintained by Locus Technologies, for analysis.

54 ENVIRONMENTAL SCIENCES↗
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 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 OSTI2024

Comparison of Projections for a Short-Term Release, CAP88 vs NARAC

The purpose of this study was to compare the projected dose using different plume models, evaluating a short duration release of tritium to the 16 compliance sectors and 4 additional points of interest using local meteorology. This report is written as guidance to the decision makers when reviewing this specific Gaussian plume model intended for radiological dose assessment and regulatory compliance, called CAP88 1 , as compared to a more-complex model designed for emergency response. The emergency response model, NARAC 2 , can be used to supplement the CAP88 compliance model evaluations, since NARAC is intended for use in situations where releases are shorter in duration and have increased complexity in terrain and meteorology.

54 ENVIRONMENTAL SCIENCES↗