ALTERNATIVE TECHNIQUE FOR PLUTONIUM STABILIZATION AND STORAGE FACILITY RISK ASSESSMENT

Overview: National Emission Standards for Hazardous Air Pollutants (NESHAPS), 40 CFR 61, is referenced by DOE Orders 5400.1, 5400.5, and 5480.7 for DOE Facility compliance. The Savannah River Site (SRS) compliance position is enumerated in the 1991 Federal Facility Compliance Agreement (FFCA). 40 CFR 61, Subpart H specifies the EPA radioactive airborne effluent monitoring requirements during normal operations and plant upsets as 10 mrem/yr. Effective Dose Equivalent (EDE) limit for the public. Risk-dominant radionuclides that exceed 1% of the standard shall be measured per monitoring and test procedures. Therefore strict adherence to 40 CFR 61 would force a radionuclide NESHAP permit for regulating routine release emissions that exceed the Potential Effective Dose Equivalent (PEDE) of 0.1 mrem/year. Further guidance is provided in Appendix D to Part 61, Methods for Estimating Radionuclide Emissions.