Washington Administrative Code › Title 246 - Health, Department of › RADIATION › Chapter 246-247 - Radiation protectionAir emissions › Section 246-247-120 - Appendix B - BARCT compliance demonstration Purpose

Current through Register Vol. 24-14, July 15, 2024
A BARCT demonstration is used to choose control technologies
				  for the mitigation of emissions of radioactive material from new emission units
				  or significant modifications to emission units. The bases for the BARCT
				  demonstration requirements are the BARCT standard given in WAC
				  246-247-040, and the definition
				  of BARCT given in WAC
				  246-247-030. This procedure
				  incorporates certain implementing criteria that enable the department to
				  evaluate a facility's compliance with the BARCT standard. It is the applicant's
				  responsibility to demonstrate the effectiveness of their BARCT determination to
				  the department. The facility should contact the department at the conceptual
				  design phase for guidance on the BARCT demonstration requirements. The
				  department may adjust this demonstration procedure on a case-by-case basis, as
				  needed, to ensure compliance with the substantive standard.
Scope.
The BARCT demonstration includes the
				  abatement technology and indication devices that demonstrate the effectiveness
				  of the abatement technology from entry of radionuclides into the ventilated
				  vapor space to release to the environment. The applicant shall evaluate all
				  available control technologies that can reduce the level of radionuclide
				  emissions.
Technology Standards.
The BARCT demonstration
				  and the emission unit design and construction must meet, as applicable, the
				  technology standards shown below if the unit's potential-to-emit exceeds 0.1
				  mrem/yr TEDE to the MEI. If the potential-to-emit is below this value, the
				  standards must be met only to the extent justified by a cost/benefit
				  evaluation.
ASME/ANSI AG-1,
Code on Nuclear Air and Gas
				  Treatment (where there are conflicts in standards with the other listed
				  references, this standard shall take precedence)
ASME/ANSI N509,
Nuclear Power Plant Air-Cleaning
				  Units and Components
ASME/ANSI N510,
Testing of Nuclear Air Treatment
				  Systems
ANSI/ASME NQA-1,
Quality Assurance Program
				  Requirements for Nuclear Facilities
40. C.F.R. 60, Appendix A,
Methods 1, 1A, 2, 2A,
				  2C, 2D, 4, 5, and 17
ANSI/HPS N13.1-1999,
Sampling and Monitoring
				  Releases of Airborne Radioactive Substances from the Stacks and Ducts of
				  Nuclear Facilities
The following standards and references are recommended as
				  guidance only:
ANSI/ASME NQA-2,
Quality Assurance Requirements
				  for Nuclear Facilities
ANSI N42.18,
Specification and Performance of
				  On-Site Instrumentation for Continuously Monitoring Radioactivity in
				  Effluents
ERDA 76-21,
Nuclear Air Cleaning Handbook
ACGIH 1988,
Industrial Ventilation, A Manual of
				  Recommended Practice, 20th ed., American Conference of Governmental Industrial
				  Hygienists
BARCT Demonstration Procedure.
Step 1.
Define facility process variables.
Describe the physical and chemical process. Include the potential radionu-clide
				  release rates (by isotope, in units of curies/year), process variables (such as
				  flow rate, temperature, humidity, chemical composition), and other technical
				  considerations. Base the radionuclide release rate on the
				  potential-to-emit.
Radionuclides selected for consideration in the BARCT
				  demonstration shall include those which contribute more than ten percent of the
				  potential TEDE to the MEI or more than 0.1 mrem/yr, and any others which the
				  department determines are necessary.
Step 2.
Gather information on all available control
				  technologies.
Search for all available technologies that can reduce the
				  emissions levels for the radionuclides selected in Step 1. Sources of
				  information shall include previous BARCT demonstrations, regulatory
				  authorities, industry or regulatory agency databases, literature searches,
				  information from technology vendors, research and development reports, and any
				  other means necessary to identify all available technologies. "Available
				  technology" includes any technology that is commercially available. Recently
				  completed searches may be used with department approval.
Step 3.
Determine technical feasibility.
Determine technical feasibility by evaluating vendor specifications for
				  available control technologies identified in Step 2 with respect to the process
				  variables identified in Step 1. Evaluate combinations of abatement technology
				  and control devices by component, and the system as a whole.
If a control technology has poor safety, reliability, or
				  control effectiveness as achieved in practice under the proposed process
				  conditions, or the technology is not applicable to the emission unit under
				  consideration, the technology may be eliminated with supporting documentation
				  of the technical infeasibility.
Step 4.
List all feasible control technologies in order
				  of effectiveness.
Evaluate feasible control technologies for efficiency
				  (effectiveness) in reducing the TEDE to the MEI. List them in order, with the
				  most effective first. If the most effective feasible technology is proposed as
				  BARCT, the demonstration is complete at this step.
Step 5.
Evaluate the environmental, energy, and
				  economic impacts.
Evaluate each control technology in succession,
				  beginning with the most effective. Present an objective evaluation considering
				  both beneficial and adverse impacts. Quantify the data where possible. Impact
				  cost and effectiveness evaluations are incremental and include only that
				  portion of the facility which comes under the authority of this chapter.
				  Evaluate at least the following impacts:
Environmental impact
- Determine the incremental
				  environmental impact, both beneficial and adverse. Evaluate the beneficial
				  impact of reduction in the TEDE to the surrounding population or, at a minimum,
				  to the MEI due to the abatement of radioactive air emissions. Consider the
				  adverse impacts from waste generation (radioactive and nonradioactive, air and
				  nonair), disposal and stabilization, construction of control equipment, and the
				  health and safety to both radiation workers and the general public.
Energy impact
- Determine the incremental energy
				  impact. Include the impact of any resulting need for new services such as
				  energy distribution systems.
Economic impact
- Determine the incremental
				  economic impact. Determine capital and expense costs including design,
				  development, procurement, construction, operation, maintenance, taxes, waste
				  disposal, and any other applicable financial components. Base all costs on the
				  expected lifetime of the emission unit and reduce to an annualized cost for
				  evaluation and comparison.
The adverse economic impact compared to the beneficial
				  impact, including reduction in TEDE to the surrounding population or the MEI,
				  is a measure of the cost versus benefit for the control technology
				  evaluated.
The most effective technology may be eliminated from
				  consideration if the applicant can demonstrate to the department's satisfaction
				  that the technology has unacceptable impacts. State clearly the basis for this
				  conclusion and proceed to the next most effective control technology. If the
				  next most effective technology is proposed as BARCT, the demonstration is
				  complete; otherwise, evaluate the control technology for impacts in accordance
				  with this step.
If the control technology cannot be eliminated on the basis
				  of its impacts, it is proposed as BARCT.
Reporting.
Prepare a BARCT compliance
				  demonstration report for department review. Provide sufficient information such
				  that the department can validate essential results. If no control technology is
				  feasible, or emissions are unacceptable, the department reserves the right to
				  prohibit the construction and operation of the emission
				  unit(s).
Statutory Authority:
					 RCW
					    70.98.050. 04-18-094, § 246-247-120,
					 filed 9/1/04, effective 10/2/04. Statutory Authority:
					 Chapters
					 70.98 and
					 70.94 RCW and chapter 173-480 WAC.
					 94-07-010, § 246-247-120, filed 3/4/94, effective
					 4/4/94.