Using real data and process knowledge to eliminate excessive NESHAP programmatic requirements
- Sandia National Labs. (United States)
- Roy F. Weston, Inc. (United States)
In 1989, the Environmental Protection Agency (EPA) promulgated Title 40 of the Code of Federal Regulations, Part 61, Subpart H, (NESHAP-40 CFR 61, Subpart H) to address radionuclide air emissions from US Department of Energy (DOE) facilities. The purpose of this paper is to identify the primary radionuclide source term contributors and use this information to eliminate excessive NESHAP programmatic requirements associated with modeling and reporting radionuclide emission sources contributing to the maximum exposed individual (MEI). Resources were made available to SNL for compliance activities associated with implementing a new NESHAP regulation. The requirements of 40 CFR 61, Subpart H were intended to limit the potential dose to members of the public resulting from radionuclide emissions from DOE facilities. However, it was difficult to envision the true impression and implications of a new regulation without actual operating experience. By acquiring a greater understanding of its potential radionuclide source term, including monitoring and reporting requirements, SNL was able to allocate resources according to those radionuclide emission sources contributing the majority of the effective dose equivalent (EDE) to the MEI. Furthermore, because resources required to maintain compliance activities after implementation are often subject to reduction, this reevaluation to eliminate excessive NESHAP programmatic requirements also demonstrates how compliance programs should be reviewed and updated annually. Moreover, as operational experience is acquired, decisions should be based on real data and process knowledge rather than relying on conservative assumptions that tend to overestimate the EDE to the MEI.
- OSTI ID:
- 298263
- Report Number(s):
- CONF-981106-; ISSN 0003-018X; TRN: 99:001895
- Journal Information:
- Transactions of the American Nuclear Society, Vol. 79; Conference: American Nuclear Society winter meeting, Washington, DC (United States), 15-19 Nov 1998; Other Information: PBD: 1998
- Country of Publication:
- United States
- Language:
- English
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