Comparison of the Current Center of Site Annual Neshap Dose Modeling at the Savannah River Site with Other Assessment...

The U.S. Environmental Protection Agency (EPA) requires the use of the model CAP88 to estimate the total effective dose (TED) to an offsite maximally exposed individual (MEI) for demonstrating compliance with 40 CFR 61, Subpart H: The National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations. For NESHAP compliance at the Savannah River Site (SRS), the EPA, the U.S. Department of Energy (DOE), South Carolina's Department of Health and Environmental Control, and SRS approved a dose assessment method in 1991 that models all radiological emissions as if originating from a generalized center of site (COS) location at two allowable stack heights (0 m and 61 m). However, due to changes in SRS missions, radiological emissions are no longer evenly distributed about the COS. An area-specific simulation of the 2015 SRS radiological airborne emissions was conducted to compare to the current COS method. The results produced a slightly higher dose estimate (2.97 × 10 mSv vs. 2.22 × 10 mSv), marginally changed the overall MEI location, and noted that H-Area tritium emissions dominated the dose. Thus, an H-Area dose model was executed as a potential simplification of the area-specific simulation by adopting the COS methodology and modeling all site emissions from a single location in H-Area using six stack heights that reference stacks specific to the tritium production facilities within H-Area. This "H-Area Tritium Stacks" method produced a small increase in TED estimates (3.03 × 10 mSv vs. 2.97 × 10 mSv) when compared to the area-specific simulation. This suggests that the current COS method is still appropriate for demonstrating compliance with NESHAP regulations but that changing to the H-Area Tritium Stacks assessment method may now be a more appropriate representation of operations at SRS.