Ambient Air Sampling for ARP Compliance with the NESHAP, Subpart H Paul Ritter State of Idaho – DEQ Oversight Program November 17, 2011

NESHAP, Subpart H Requirements The NESHAP limits INL dose to the maximally exposed individual (MEI) to 10 mrem/y. To determine compliance, radionuclide emissions shall be determined…dose to MEI calculated…using EPA approved sampling procedures, models [CAP–88], or other EPA-approved procedures. Emission measurement for a source is required if potential dose exceeds 0.1 mrem.

NESHAP, Subpart H Requirements (cont.) Alternatively, with prior EPA approval… Environmental measurements of radionuclide air concentrations at critical receptor locations may be used as an alternative to air dispersion calculations in demonstrating compliance with the standard if the owner or operator meets the following criteria…[40 CFR 61.93(g)].

40 CFR 61.93(g) Requirements 1.The air shall be continuously sampled. 2.Major contributors to dose must be measured. 3.Concentrations that would cause a 1 mrem/y dose shall be readily detectable and distinguishable from background. 4.Net measured concentrations must be compared to concentrations in Table 2, appendix E, to determine compliance. 5.Implement a QA program meeting performance requirements of Appendix B, Method 114. Also, EPA guidance, Methods for Estimating Fugitive Emissions from Diffuse Sources at DOE Facilities. (section 6 covers sampling for NESHAP compliance)

Critical Receptor Locations Possibilities… Historical INL MEI location – Frenchman’s Cabin EPA guidance for estimating diffuse emissions: “...For facilities with continuous emissions, the critical receptor locations may be either: (a) The location of the highest Chi/Q on the facility perimeter fence line…or, (b) the location of the highest off-site Chi/Q where a residence, business, or school exists”; i.e., the maximally exposed individual (MEI) per the NESHAP.

ARP Source Characteristics Multiple confinement structures – tall with large footprints – Conservative wind-load modeling indicates building leakage is the dominant release path Any releases would be at ground-level, with multiple structures nearby

CAP-88PC Calculations Evaluated annual average air concentrations caused by ARP at candidate sampling locations; determined that the EBR-1 area is a reasonable surrogate ARP MEI location Estimated air concentrations near the RWMC perimeter

Sampling Design and Operations Program designed to meet requirements for… Measurement sensitivity – Table 2, Appendix E Data completeness – 80%

Measurement Sensitivity ‘Concentrations causing 1 mrem…comparison to 40CFR61 Appendix E, Table 2 concentrations’ – App. E concentrations correspond to 10 mrem/y. Pu-239 and Am-241 limiting concentration levels, 2.0E-15 Ci/m3 and 1.9E-15 Ci/m3. Achieved… detection limits for the ARP measurements of Pu-239 and Am-241 range from 1 to 5 and 2 to 6 E-18 Ci/m 3.

Sampling Equipment Hi volume air samplers operated at 20 scfm (about 24 acfm) Pall Versapore 3000 filters; 8” by 10” – Recommended in ANSI N13.1 (1999) – >99.7% collection, with relatively high permeability – Bulk rolls available; 500’ by 10” wide for ~$3000 Digital and analog calibrators

Sampling and Analysis Schedule Every 2 weeks… Duplicate samples taken the EBR-1 power pole Backup sample taken at the EBR-1 fence Background sample taken at Howe Analysis on monthly composites Gamma spectrometry -- dissolved filters Radiochemistry for TRU nuclides, 90 Sr

Sampling and Analysis Schedule (cont.) Semi-monthly collection; Monthly composite Duplicate samples for each month for QC and assessment of representativeness. Backup samples are archived – analyzed if there are lab problems or questions regarding the routine ARP program samples, or data from other site monitoring organizations. Monthly schedule for analysis is compatible with 80% data completeness goal.

Operating Experience Analysis of 8” by 10” Versapore 3000 filters was a challenge for our first lab, but no problem for the second. No problems with air samplers – biweekly sampling period is no problem Redundant sampling locations are a good idea Archived backup samples are a good idea

Questions?