TAM-B - Special Session: Rad NESHAP Woodrow Wilson B 08:00 - 12:00
|
| Chair(s): Matthew Barnett, Christine Lobos
|
| |
TAM-B.1
08:00 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 activities that have taken place in the past year and presents brief case studies on those developments that either have a broad effect on the regulated community or are of particular interest to the health physics community. In 2022 and 2023, EPA observed a continuing trend of increased regulatory activity related to the management of phosphogypsum, including radon flux measurement performed for stack closure, and risk assessment related to the reuse of phosphogypsum.
|
TAM-B.2
08:30 DOE Subpart H Report CM Lobos*, DOE-HQ, EHSS-22
; SF Snyder, PNNL- Richland, WA
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 2021 radioactive emissions and compliance status is presented. The 2021 results relative to other recent years are also presented.
|
TAM-B.3
09:00 ANSI N13.1 Criteria Explained BC Blunt*, Blunt Consulting LLC
Abstract: ANSI N13.1 contains criteria for selecting a suitable sample location based on test data from the actual stack, a scale model or a geometrically similar stack or duct. Experimental data that was not made public, as well as requirements from the Environmental Protection Agency regulations was used to establish these criteria. This presentation will provide background information and justification for several of the N13.1 criteria. Topics to be addressed include the 20% COV criteria and the criteria for similar stack evaluations. The 20% COV values are used for velocity, gaseous tracer and particulate tracer testing. The Standard allows a stack that is within six times the velocity times the diameter of a subject stack to be used as basis for the selection of the representative sample location in the subject stack. Other criteria used throughout the Standard will be discussed as time and interest permits. One example would be criteria for requiring that the sample flow rate for a PIC 1 source be varied based on the stack flowrate.
|
TAM-B.4
09:30 BREAK
|
TAM-B.5
10:00 De Minimis Criteria Value for Compliance with 40 CFR 61 Subpart H Diffuse Source Requirements JA Cummings*, Lawrence Berkeley National Lab
Abstract: Lawrence Berkeley National Lab (LBNL) is subject to U.S. Environmental Protection Agency (EPA) 40 CFR 61 Subpart H, National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities, as well as U.S. Department of Energy Order 458.1, Radiation Protection of the Public and the Environment and State of California regulations. Thus, radioactive air emissions must be accounted for whenever soil that has the potential to contain radionuclides above background is excavated or disturbed within LBNL’s developed area. The developed area refers to the geographic area of LBNL’s main site where lab infrastructure is currently present or there was historical infrastructure where radiological work was conducted. To reduce unnecessary effort while complying with regulations, LBNL implemented a de minimis criteria value to include in the site’s annual radioactive air emissions report that accounts for these fugitive emissions, and presented this methodology to EPA Region 9 and EPA Headquarters personnel for concurrence. This de minimis criteria value was calculated using EPA’s Clear Air Assessment Package software with site-specific parameters and a source term conservatively-modeled at site-specific Derived Concentration Guideline Levels produced via the RESidual RADioactivity software.
|
TAM-B.6
10:30 U.S. Environmental Protection Agency Update on Compliance Codes B Littleton*, EPA
; D Stuenkel, EPA
Abstract: The U.S. Environmental Protection Agency (EPA) maintains computer codes used to demonstrate compliance with public dose limits set by its radionuclide National Emission Standard for Hazardous Air Pollutants (NESHAPs) program. The Agency has recently made available a minor update in CAP88-PC Version 4.1.1. Some potential updates that the Agency is considering are: 1) a web-based compliance system, 2) modifications to accommodate the most recent population data in localities, and 3) updates to the agricultural data from which the food source categories are developed. Potential updates to the Agency’s COMPLY code include options to make the model more user-friendly. Other potential updates will be presented. The Agency will also be previewing a revision to it’s COMPLY-R code which allows users to show compliance with its NESHAPs Subpart B requirements applicable to active uranium mining facilities. Updates to all compliance codes will be discussed, and user input will be solicited for these future updates.
|
TAM-B.7
11:00 Methods for Dose Tracking from Project Emissions for 40CFR61, Subpart H Compliance AM Harshman*, Oak Ridge National Lab
; WL McCarter, Oak Ridge National Lab
Abstract: US Department of Energy (DOE) national laboratories can play a crucial role in the treatment of certain medical conditions by conducting research and development in specialized facilities which also have the ability to produce essential radiopharmaceuticals. Since 2017, Oak Ridge National Laboratory has had an ongoing project in the production and supply of a critical radiopharmaceutical, Ac-227, which is used to treat certain types of cancer. Airborne radioactive emissions can be released as a result of radioisotope production activities. Airborne radioactive emissions released from DOE complex facilities are subject to Clean Air Act regulations presented in 40 CFR Part 61, Subpart H, which includes an effective dose limit to a maximally exposed offsite member of the public. In order to optimize Ac-227 production and to limit doses to the maximally exposed offsite member of the public, doses from project emissions have been tracked on a monthly basis. Dose tracking data were compiled from the Ac-227 project for the previous four years and analyzed to establish dose estimation methods that could effectively be used to predict project doses on a frequent or periodic basis, allowing for compliance with relevant regulations while optimizing production of Ac-227.
|
TAM-B.8
11:30 Roundtable
|
