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Policy Area

ESH-Environment Safety & Health

Procedure Number

ESH100.2.ENV.14

Procedure Title

Comply with Radionuclide National Emissions Standards for Hazardous Air Pollutants

Procedure Manager

COOPER, TERRY W.

Status

Active

Subject Matter Expert

  • Mark L. Miller
  • Robert C. Holland (CA)

Applicability, Exceptions, and Consequences

This procedure applies to Members of the Workforce whose activities at SNL/NM and TTR release or have the potential to release radionuclides into the environment through an air emission. This procedure does not apply to other Sandia-controlled premises.

Exceptions to, or deviations from this procedure must be approved through the Executive Policy Sponsor or Policy Area Manager, if delegated. Click here to view Contacts for Corporate Policy System Policies, Processes, and Procedures. See CG100.1.7, Request an Exception to a Policy, Process, or Procedure, for directions on how to obtain an exception to this procedure.

Granting or permitting exceptions or violations of policy, process, or procedure without authority, regardless of position or title, may be cause for disciplinary action up to and including termination of employment. Violating a policy, process, or procedure may be cause for disciplinary action up to and including termination of employment.

IMPORTANT NOTICE: A printed copy of this document may not be the document currently in effect. The official version is located on the Sandia National Laboratories Sandia Restricted Network (SRN).

Procedure Overview

This procedure describes the requirements for Members of the Workforce to follow when radionuclide National Emissions Standards for Hazardous Air Pollutants (NESHAP) sources affect activities at SNL/NM and TTR.

Procedure Requirements

Establishment of Radionuclide National Emissions Standards for Hazardous Air Pollutants (NESHAP) Compliance at SNL/NM

Activity Responsible Individual Required Action
Initiate Compliance with Radionuclide National Emissions Standards for Hazardous Air Pollutants (NESHAP) (at SNL/NM) Source Owners

Coordinate with the radiological NESHAP contact to:

  • Identify annual radiological emission limits for facilities (radionuclide emissions to the ambient air not exceed those amounts that would cause any member of the public to receive in any year an effective dose of 10 mrem per year).
  • Identify radionuclide NESHAP sources, evaluate new or modified radionuclide sources, and evaluate the design and development of new facilities for regulatory compliance.
  • Establish air emission inventories for radionuclide NESHAP sources before planning to modify:
    • A facility or begin new construction that has the potential to be or become a radionuclide NESHAP source.
    • An existing radionuclide source.
  • Conduct a preliminary dose assessment.
  • Obtain local air quality permits (see ESH100.2.ENV.12, Obtain and Comply with Air Permits, for more information, or federal construction or modification approvals).
Implement Required Monitoring Source Owners
  • Monitor releases from each radiological NESHAP source that could cause the maximally exposed individual (MEI) to receive an effective dose of greater than or equal to 0.1 mrem per year per the requirements in 40 CFR 61, Subpart H, "National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities."
  • Retain original logs (i.e., installation, calibration, testing) associated with monitoring equipment for 5 years.
Develop a Quality Assurance Plan Source Owners
  • Coordinate with the radiological NESHAP contact to ensure that a quality assurance plan is written to document radiological NESHAP compliance activities for radionuclide NESHAP sources at their facility that require monitoring.
  • Ensure that this quality assurance plan includes the components specified in 40 CFR 61, Subpart H, "National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities."

Notes: The following are exempt from radionuclide NESHAP requirements:

  • Radioactive sources that are located within equipment and used for their intended purposes (and are unmodified).
  • Sealed radioactive sources (see MN471016, Radiological Protection Procedures Manual, for more information).

Establishment of Radionuclide National Emissions Standards for Hazardous Air Pollutants (NESHAP) Compliance at SNL/CA

Activity Responsible Individual Required Action
Initiate Compliance with Radionuclide National Emissions Standards for Hazardous Air Pollutants (NESHAP) (at SNL/CA) Source Owners

Coordinate with the radiological NESHAP contact to:

  • Identify annual radiological emission limits for facilities (radionuclide emissions to the ambient air shall not exceed those amounts that would cause any member of the public to receive in any year an effective dose of 10 mrem per year).
  • Identify radionuclide NESHAP sources, evaluate new or modified radionuclide sources, and evaluate the design and development of new facilities for regulatory compliance.
  • Establish air emission inventories for radionuclide NESHAP sources before planning to modify:
    • A facility or begin new construction that has the potential to be or become a radionuclide NESHAP source.
    • An existing radionuclide source.
  • Conduct a preliminary dose assessment.
  • Obtain local air quality permits (see ESH100.2.ENV.12, Obtain and Comply with Air Permits, for more information) or federal construction or modification approvals.

Notes: 

  • At SNL/CA, all radioactive sources are checked against the 40 CFR 61, Subpart H, "National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities," Appendix E, “Annual Possession Quantities” (SNL/CA and Lawrence Livermore National Laboratory (LLNL) have permission from EPA Region IX to use this appendix for this purpose) by the SNL/CA NEHAPS point of contact. 
  • If the amount is below the Annual Possession Quantity, the project can proceed.
  • If the amount is above the Annual Possession Quantity, the SNL/CA NESHAPS point of contact gathers the pertinent information and uses the CAP88-PC dose code to determine if other controls (such as monitoring) are required.
Implement Required Monitoring Source Owners

Ensure that:

  • Releases from each radiological NESHAP source that could cause the maximally exposed individual (MEI) to receive an effective dose equivalent (EDE) of greater than or equal to 0.1 mrem per year is monitored according to the requirements in 40 CFR 61, Subpart H, "National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities."
  • Original logs (i.e., installation, calibration, testing) associated with monitoring equipment are retained for 5 years.
Develop a Quality Assurance Plan Source Owners
  • Work with the radiological NESHAP contact to ensure that a quality assurance plan is written to document radiological NESHAP compliance activities for radionuclide NESHAP sources at their facility that requires monitoring.
  • Ensure that this quality assurance plan includes the components specified in 40 CFR 61, Subpart H, "National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities."

Maintenance of Radionuclide National Emissions Standards for Hazardous Air Pollutants Compliance

Activity Responsible Individual Required Action
Maintain Compliance with Radionuclide National Emissions Standards for Hazardous Air Pollutants (NESHAP) Members of the Workforce Report abnormal or accidental (unplanned) releases according to procedures in ESH100.4.RPT.4, Report Environmental Releases.
Maintain Compliance with Radionuclide National Emissions Standards for Hazardous Air Pollutants (NESHAP) Source Owners
  • Submit a Radionuclide Air Emission Inventory Form (SF 2001-RIF [Word file/Acrobat file]) once a year to the radiological NESHAP contact.
  • Notify the radiological NESHAP contact before modifying, moving, or otherwise altering a radionuclide NESHAP source or associated infrastructure.

Implementing Tools

Form

  • Radionuclide Air Emission Inventory Form (SF 2001-RIF [Word file/Acrobat file]).

Website

  • Radiological NESHAP.

Additional Drivers

  • DOE/EP-0096, A Guide for Effluent Radiological Measurements at DOE Installations, July 1983.
  • 40 CFR 61, Subpart H, National Emission Standards for Emissions of Radionuclides Other Than Radon From Department of Energy Facilities, Appendix E, “Annual Possession Quantities.”

 

Related Processes and Procedures

Processes

Procedures

Change Summary

Date Summary
8/22/2011

Administrative

Modified

Updated link to the "radiological NESHAP" contact throughout the document.
12/16/2010

Administrative

Modified

  • Updated links to 40 CFR 61, Subpart H throughout the procedure.
  • Updated SAPLE links to subject matter experts for system consistency.
  • Updated links to dictionary terms to term identification numbers for system consistency.
  • Removed extra blank line in Applicability field.
04/30/2010

Administrative

Modified

  • Corrected links to definitions of the terms "effective dose," "radionuclide NESHAP sources," "facility," "construction," "dose assessment," and "maximally exposed individual."
04/21/2010

Administrative

Modified

  • Corrected links to definitions of the terms "effective dose," "radionuclide NESHAP sources," "facility," "construction," "dose assessment," and "maximally exposed individual."