Single Session

[Schedule Grid]

TAM-E - Special Session: Rad Air NESHAPs

Room 302AB   09:30 - 11:00

Chair(s): Sandra Snyder, Michael Stewart
TAM-E.1   09:30  U.S. Environmental Protection Agency Update on the Radionuclide NESHAPs JP Walsh*, U.S. EPA ; JH Rustick, U.S. EPA

Abstract: Under the Clean Air Act, the U.S. Environmental Protection Agency (EPA) has regulatory authority over several categories of sources that have the potential to emit radionuclides into the ambient environment through the air pathway. The National Emission Standards for Hazardous Air Pollutants (NESHAPs) for radionuclides include eight subparts of 40 CFR Part 61, which apply to underground uranium mines (Subpart B), Department of Energy and Naval facilities (Subparts H, Q, and I), elemental phosphorus plants (Subpart K), phosphogypsum stacks (Subpart R), and uranium mill tailings impoundments (Subparts T and W). The radionuclide NESHAPs are implemented by the EPA’s Office of Radiation and Indoor Air, EPA Regional offices, and several delegated State governments. This presentation reviews significant recent activities that have taken place in the past year such as regulatory guidance and Agency approvals of requests by regulated parties. Brief case studies are presented for those developments that either have a broad effect on the regulated community or are of particular interest to the health physics community.

TAM-E.2   09:45  U.S. Environmental Protection Agency Update on Compliance Codes BK Littleton, U.S. Environmental Protection Agency ; DO Stuenkel*, U.S. Environmental Protection Agency

Abstract: The U.S. Environmental Protection Agency (EPA) maintains several computer codes used to demonstrate compliance with public dose limits set by 40 CFR 61, National Emission Standards for Hazardous Air Pollutants (NESHAPs). These include CAP-88 PC, COMPLY, and COMPLY-R. COMPLY-R, COMPLY, and CAP88-PC are intended for demonstrating compliance with 40 CFR 61 Subparts B, I, and H, respectively. EPA has completed Version 4.1.1 of CAP88-PC, Version 1.0.2 of the STARGET Utility, and Version 1.3 of COMPLY-R. Version 4.1.1 of CAP88-PC. Version 4.1.1 fixes a number of bugs in Version 4.1. STARGET is a stand-alone code to convert meteorological data from the stability array (STAR) file format to the "wind file" format required by CAP88-PC. EPA has updated COMPLY-R to run under the currently supported 32 and 64-bit Windows operating systems. EPA plans to next update the tritium, carbon-14, and “Radon-Only” in CAP88-PC. All NESHAPs compliance, along with associated documentation can be downloaded from the EPA’s website (

TAM-E.3   10:00  DOE Subpart H Report M Stewart, DOE-HQ ; SF Snyder*, PNNL

Abstract: Each U.S. Department of Energy site with radionuclide emissions to air is required to determine compliance with the 40 CFR 61, Subpart H, NESHAP standard, annually. A summary of DOE Site calendar year 2020 radioactive emissions and compliance status is presented. The 2020 results relative to other recent years are also presented.

TAM-E.4   10:15  Regulatory Overview of Compliance with Washington State Radioactive Air Emissions Regulations During Cleanup of a Breached Cs-137 Irradiator Sealed Source PJ Martell*, Washington State Department of Health ; JW Schmidt, Washington State Department of Health - Retired

Abstract: In May of 2019 a Cs-137 research irradiator sealed source was inadvertently breached at the Harborview Medical Center Research and Training Building (HRT) in downtown Seattle. The irradiator was being removed and disposed of by the University of Washington (UW), as part of the National Nuclear Security Administration (NNSA) Off Site Source Recovery Program (OSRP). The breach resulted in the spread of contamination throughout the HRT Building as well as into the environment and some of the surrounding buildings. This presentation provides a regulatory overview of the issues associated with compliance to the radioactive air emissions regulations in Washington State during the recovery and eventual successful cleanup of the HRT. The establishment of temporary ventilation and the need for the rapid establishment of air sampling and analysis, to detect potential contamination spread from both fugitive and stack emissions to ensure public health was protected, provided numerous challenges. This required flexibility by both the contractors and regulatory personnel performing initial retrieval of the breached source, as well as during the long-term remediation of the HRT.

TAM-E.6   10:30  Surrogate Selection and Methods to Account for Omitted Radionuclides in CAP88PC AM Harshman*, Oak Ridge National Laboratory ; PA Scofield, Strata-G

Abstract: Radioactive airborne emissions resulting from routine operations at Department of Energy (DOE) facilities, which are released into the environment and have the potential to expose the public, are regulated by 40 CFR Part 61, Subpart H, with enforcement from the U.S. Environmental Protection Agency. CAP-88 PC (Clean Air Act Assessment Package – 1988) software is used for regulatory compliance to model airborne emissions and their resulting doses to members of the public. Although the latest versions of CAP-88 contain data for 1,252 radionuclides, there are radioisotopes emitted from DOE facilities which are not in the current CAP-88 radionuclide library. Radionuclides omitted from CAP-88 must still be included when evaluating doses to members of the public through use of surrogate radionuclides or other methods. Rationale and criteria for selection of surrogate radionuclides is provided as well as an examination of other methods that can be used to account for CAP-88 omitted nuclides to ensure compliance with Clean Air Act regulations.

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