silo 3 - U.S. Department of Energy

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Silo 3-Environmental-C-ontrol-Plan- ~
40430-PL-0005, Rev. C
---mJACOBS Jacobs Project Number 35H19605 @
September 23, 2003
2.0 AIR EMISSIONS CONTROL PLAN
The Stack Release Considerations for the Silo 3 Project document (Doc. No. 40430-CA-
0003) calculates the potential emissions of air contaminants during the operation of the
Silo 3 Project. Primary sources of air contaminants are expected to be Silo 3, the process
equipment and the process building. The locations of the sources of potential air emissions
are illustrated on the Civil Site Plan, (Drawing 94X-3900-6-01297) and the Process Flow
Diagram (Drawing 94X-3900-F-01431).
Because of the physical nature of Silo 3 Material and its high thorium-230 content, control
of airborne particulate emissions is a key criterion in designing the emission control and
monitoring systems. The air emission control systems for the Silo 3 Project have been
designed to Best Available Technology (BAT) in accordance with Ohio Administrative Code
(OAC), Section 3745-31 -05(a)(3), and to meet Applicable or Relevant and Appropriate
Requirements, the As Low As Reasonably Achievable (ALARA) requirement, and other
applicable requirements.
For radionuclide particulate emission sources at the FEMP, the Ohio Environmental
Protection Agency (OEPA) has specified that BAT is the use of high-efficiency particulate
air (HEPA) filters. The use of HEPA filters is also required for compliance with 40 Code of
Federal Regulations (CFR) 61, Subpart H. HEPA filters, pre-filters, and housing assemblies
will be obtained in accordance with Silo 3 Project Technical Specifications and Project
Quality Procedure 7.1, "Control of Purchased Items and Services." The air from the stack
will also be filtered using ULPA filters as an additional measure of particulate emission
control.
Emission of radionuclide particulate materials will meet the requirements of 40 CFR Part
61, Subpart H, National Emission Standards for Hazardous Air Pollutants (NESHAP). 40
CFR Part 61.92, states that emissions of radionuclides to the ambient air from DOE
facilities shall not exceed those amounts that would cause any member of the public to
receive in any year an effective dose equivalent (EDE) of 10 millirem (mrem)/year or
greater. NESHAP Subpart H also specifies continuous monitoring for certain point sources
(stacks or vents).
Radon emissions will be monitored during the Silo 3 Project to verify that the site fence
line's radon concentration will not exceed an annual average of 0.5 picocuries per liter
(pCi/L) above background.
The Silo 3 air emission control systems are depicted by drawings 94X-3900-F-01429,
94X-3900-F-01431, and 94X-3900-H-01349. The major components of the emission
control systems are detailed below in the following sections.
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