Radioactive air emissions notice of construction portable temporary radioactive air emission units - August 1998

Abstract

This notice of construction (NOC) requests a categorical approval for construction and operation of three types of portable/temporary radionuclide airborne emission units (PTRAEUs). These three types are portable ventilation-filter systems (Type I), mobile sample preparation facilities (Type II), and mobile sample screening and analysis facilities (Type 111). Approval of the NOC application is intended to allow construction and operation of the three types of PTRAEUs without prior project-specific approval. Environmental cleanup efforts on the Hanford Site often require the use of PTRAEUs. The PTRAEUs support site characterization activities, expedited response actions (ERAs), sampling and monitoring activities, and other routine activities. The PTRAEUs operate at various locations around the Hanford Site. Radiation Air Emissions Program, Washington Administrative Code (WAC) 246-247, requires that the Washington State Department of Health (WDOH) be notified before construction of any new emission that would release airborne radioactivity. The WDOH also must receive notification before any modification of an existing source. This includes changes in the source term or replacement of emission control equipment that might significantly contribute to the offsite maximum dose from a licensed facility. During site characterization activities, ERAs, sampling and monitoring activities, and other routine activities, the PTRAEUs might require startup immediately. The notification period hampers efforts to complete such activities in an effective and timely manner. Additionally, notification is to be submitted to the WDOH when the PTRAEUs are turned off. The U.S. Department of Energy, Richland Operations Office (DOE-RL) potentially could generate several notifications monthly. The WDOH would be required to review and provide approval on each NOC as well as review the notices of discontinued sources. The WDOH regulation also allows facilities the opportunity to request a single categorical license that identifies limits and conditions of operations for similar multipurpose temporary and or portable emission units. The DOE-RL will submit annually to the WDOH a report summarizing the log books maintained on the individual PTRAEUs that are used during the reporting period. The report will supply information needed to ensure compliance with the condition of operations. The NOC includes a general description of the three types of PTRAEUs, tracking mechanisms, emissions control systems, and radioactivity handling limits (RHLs) for the PTR4EUs. The NOC is based on hypothetical data to demonstrate how emission estimates could be calculated. Tracking will be performed and monitoring will be conducted for compliance with both federal and state regulations. Type I units will use a single isotope based on a calculated RHL (source term) to determine emissions, dose, and monitoring requirements. Type I1 and 111 units will use field data and process knowledge to determine emissions, dose, and monitoring requirements. New PTRAEUs that conform to any of the three types of PTRAEUs described in this application will be added to the next annual report after the units are placed in service. New PTRAEUs, which do not conform to any of the three types of PTRAEUs described in this application, will require approval on an individual basis by the WDOH before startup.