A reevaluation of the National Emission Standards for Hazardous Air Pollutants (NESHAP - 40 CFR 61, Subpart H) program at Sandia National Laboratories, New Mexico

The initial National Emission Standards for Hazardous Air Pollutants (NESHAP - 40 CFR 61, Subpart H) Program at Sandia National Laboratories, New Mexico (SNL/NM) required: (1) continuous air monitoring of sources if the calculated effective dose equivalent (EDE) to the maximum exposed individual (MEI) was > 0.1 mrem/yr; (2) the determination of emissions based on measurements or measured parameters if the EDE to the MEI was < 0.1 mrem/yr; and (3) the calculation of worst case releases when the expected air concentrations were below detection limits using standard monitoring equipment. This conservative interpretation of the regulation guided SNL/NM to model, track, and trend virtually all emission sources with the potential to include any radionuclides. The level of effort required to implement these activities was independent of the EDE contributing from individual sources. A recent programmatic review found the NESHAP program to be in excess of the legal requirements. A further review found that, in summation, 13 of 16 radionuclide sources had a negligible impact on the final calculated EDE to the MEI used to demonstrate compliance at 20 separate on-site receptor locations. A reevaluation was performed to meet the legal requirements of 40 CFR 61, Subpart H, and still be reasonable and appropriate under the existing circumstances