Implementation of New Rad-NESHAP Requirements at LANL LA-UR-03-8357
D. P. Fuehne, V. A. Martinez, H. A. Martinez, K. I. Anderson, R. W. Sturgeon
Title 40 of the Code of Federal Regulations, Chapter 61, Subpart H, is the section of the Clean Air Act that regulates the emissions of airborne radioactive material from Department of Energy (DOE) facilities. Recent revisions to this regulation incorporated requirements from the stack sampling national standard, ANSI/HPS N13.1-1999. This standard imposes inspection and maintenance requirements on stack sampling systems and also establishes design criteria for new sampling systems. Los Alamos National Laboratory (LANL) has developed and implemented a stack inspection program for all monitored stacks. These inspections include internal inspection via borescope for particulate stacks, in-place source testing for tritium-emitting stacks, and leak measurements at the stacks with highest emissions levels. Results of these stack inspections have shown no performance issues with the majority of stacks at LANL. Some stack sample systems required mild cleaning or replacement of components. While existing stack sampling system designs throughout the DOE complex are approved by a "grandfather" clause in the new Rad-NESHAP revision, LANL undertook a study to compare certain existing LANL designs with ANSI/HPS N13.1-1999 design criteria. With the results from this study, LANL has developed a library of stacks and associated sampling systems that meet the ANSI criteria and that can be used to design other ventilation systems at new facilities. For high-emissions sources, the ANSI standard also requires continuous monitoring of stack and sample flow rates and real-time emissions measurements. At LANL's main accelerator complex, these requirements are met by linking flow indicators and emissions monitors into the accelerator's central control room computer system. With this setup, flow and emissions levels are automatically compared with acceptance criteria, and deviations from these criteria result in alarms or other notifications to emissions measurement personnel.
This abstract was presented at the 37th Annual Midyear Meeting, "Air Monitoring and Internal Dosimetry", Effluent and Environmental Monitoring Session, 2/8/2004 - 2/11/2004, held in Augusta, GA.