Pacific Northwest National Laboratory Potential Impact Categories for Radiological Air Emission Monitoring

In 2002, the EPA amended 40 CFR 61 Subpart H and 40 CFR 61 Appendix B Method 114 to include requirements from ANSI/HPS N13.1-1999 Sampling and Monitoring Releases of Airborne Radioactive Substances from the Stack and Ducts of Nuclear Facilities for major emission points. Additionally, the WDOH amended the Washington Administrative Code (WAC) 246-247 Radiation protection-air emissions to include ANSI/HPS N13.1-1999 requirements for major and minor emission points when new permitting actions are approved. A result of the amended regulations is the requirement to prepare a written technical basis for the radiological air emission sampling and monitoring program. A key component of the technical basis is the Potential Impact Category (PIC) assigned to an emission point. This paper discusses the PIC assignments for the Pacific Northwest National Laboratory (PNNL) Integrated Laboratory emission units; this revision includes five PIC categories.