DOE/ORO/2327 Oak Ridge Reservation Annual Site Environmental ...

Oak Ridge Reservation
3-16 East Tennessee Technology Park
Fig. 3.4. TSCA Incinerator.
emissions from all remaining sources not to exceed the annual threshold limit, ETTP would not be subject
to mandatory annual reporting under the GHG Rule beginning with the 2010 calendar year.
Prior to December 2, 2009, and the subsequent ceasing of operations, ETTP airborne discharges from
the TSCA Incinerator were generated while treating solid and liquid wastes from residual contamination,
waste storage and treatment operations, site remediation and demolition activities, and site maintenance
support activities. The primary source of radiological emissions at ETTP was the TSCA Incinerator which
was the major active airborne radionuclide emission source at ETTP regulated under National Emission
Standards for Hazardous Air Pollutants for Radionuclides (rad NESHAP) for DOE facilities. The TSCA
Incinerator was equipped with extensive exhaust gas pollution control equipment, enabling it to operate in
regulatory compliance with both the federal Clean Air Act (CAA) and the Tennessee Air Code.
Characterization of the impact on public health of radionuclides released to the atmosphere from
ETTP operations was accomplished by conservatively estimating the dose to the maximally exposed
member of the public. The dose calculations were performed using the Clean Air Assessment Package
(CAP-88) computer codes, which were developed under sponsorship of the U.S. Environmental
Protection Agency (EPA) for use in demonstrating compliance with the rad NESHAP emission standard.
Source emissions used to calculate the dose are determined using EPA approved methods ranging from
continuous stack sampling systems to conservative estimations based on process and waste
characteristics. Continuous sampling systems and permitting are required for radionuclide emitting
sources that have the potential dose not less than 0.1 mrem per year impact on the most exposed member
of the public. The TSCA Incinerator and the K-1423 Solid Waste Repack Facility (K-1423) are the only
ETTP sources that have permitted limitations for radionuclide emissions and require continuous sampling
systems. ETTP rad NESHAP sources K-1093/K-1094 Waste Sorting Tent, K-1407 Central Neutralization
Facility (CNF), K-1423, and the K-2500-H Segmentation Shops A and D are considered minor based on
emissions evaluations using EPA approved calculation methods.
The TSCA Incinerator was the only operating source at ETTP required by rad NESHAP regulation to
directly monitor stack emissions continuously for radionuclide emissions due to the potential to emit.
During the 2009 period of performance, the TSCA Incinerator contributed approximately 8% of the total