Monitoring plan for routine organic air emissions at the Radioactive Waste Management Complex Waste Storage Facilities

This monitoring plan provides the information necessary to perform routine organic air emissions monitoring at the Waste Storage Facilities located at the Transuranic Storage Area of the Radioactive Waste Management Complex at the Idaho National Engineering Laboratory. The Waste Storage Facilities include both the Type I and II Waste Storage Modules. The plan implements a dual method approach where two dissimilar analytical methodologies, Open-Path Fourier Transform Infrared Spectroscopy (OP-FTIR) and ancillary SUMMA{reg_sign} canister sampling, following the US Environmental Protection Agency (EPA) analytical method TO-14, will be used to provide qualitative and quantitative volatile organic concentration data. The Open-Path Fourier Transform Infrared Spectroscopy will provide in situ, real time monitoring of volatile organic compound concentrations in the ambient air of the Waste Storage Facilities. To supplement the OP-FTIR data, air samples will be collected using SUMMA{reg_sign}, passivated, stainless steel canisters, following the EPA Method TO-14. These samples will be analyzed for volatile organic compounds with gas chromatograph/mass spectrometry analysis. The sampling strategy, procedures, and schedules are included in this monitoring plan. The development of this monitoring plan is driven by regulatory compliance to the Resource Conservation and Recovery Act, State of Idaho Toxic Air Pollutant increments, Occupational Safety and Health Administration. The various state and federal regulations address the characterization of the volatile organic compounds and the resultant ambient air emissions that may originate from facilities involved in industrial production and/or waste management activities.