TITLE

ES&H Manual

 

DOCUMENT ID

8030 Air Quality

 

1.0          Purpose

Air quality in Virginia is regulated on both the federal and state levels.  The Clean Air Act  (CAA; [42 U.S.C. §7401 et seq.]) and Environmental Protection Agency Air Programs (40 CFR Chapter 1, Subchapter C, Parts 50-99) are the federal-level air quality regulations.  On the state level, air quality is regulated under the Virginia Air Pollution Control Laws and the Virginia Administrative Code (VAC; [9VAC5-10 through 5-540, State Air Pollution Control Board]).  These regulations are administered by the State Air Pollution Control Board and the Virginia Department of Environmental Quality (DEQ).

TJNAF abides by all federal and state air quality regulations, along with the requirements of DOE O 458.1 Chg 4 (LtdChg), Radiation Protection of the Public and Environment and DOE O 436.1, Departmental Sustainability.

2.0          Scope

The Lab’s Air Quality Program focuses on identifying and minimizing emissions from all sources that have the potential to impact ambient air quality. The goals of the program include:

·       identifying potential air quality issues during experiment, task, and project review.

·       utilizing proper control measures to reduce or eliminate air pollutants from on-site operations, facilities, and equipment.

·       maximizing the use of safe alternatives to ozone depleting substances (ODSs), hazardous air pollutants (HAPs) and materials containing volatile organic compounds (VOCs).

·       abiding by all applicable regulatory requirements described in this chapter.

3.0          Responsibilities

Note:   Management authority may be delegated to a task-qualified TJNAF employee at the discretion of the responsible manager.

3.1           Everyone at Jefferson Lab

·       participate in the planning process to identify new or modified emission sources

·       report unusual emissions from laboratory operations

·       manage Sulfur Hexafluoride (SF6) per this procedure

3.2           Facilities Management & Logistics

·       maintain Test Lab scrubbers and boilers

·       ensure subcontractor certifications for refrigerant system maintenance

·       track emergency generator usage

3.3           Radiation Control Personnel

·       manage and report radionuclide emissions per National Emission Standards for Hazardous Air Pollutants (NESHAPs)

·       establish compliance strategies for new or modified emission sources

4.0          Expectations

Known emission sources, chemical and potential regulated pollutants, and the associated control measures are summarized in the following table. In most cases, these emissions are well below regulatory thresholds that would require state or federal permits.

Subsections of 4.0 describe specific policies, procedures, or other operational controls placed upon Lab activities and emission sources to ensure compliance with specific regulatory elements or best practices.

 

Known Emission Sources

Source

Air Pollutant(s)

Chemicals or Compounds

Compliance or

Control Measure(s)

Applicable Regulation(s)

Cavity-cleaning operations

 

(Test Lab)

VOCs, HAPs, hydrogen

Isopropyl alcohol, Methanol

scrubbers

40 CFR Part 61, National Emission Standards for Hazardous Air Pollutants (NESHAPs)

 

9VAC5-60, Hazardous Air Pollutants Sources

Niobium cavity acid etching

 

(Test Lab)

NOx

Nitric acid, Hydrofluoric acid

scrubbers

40 CFR Part 50, Standards for Criteria Pollutants

Experimental equipment usage

 

(CEBAF, LERF, Test Lab, ARC)

GHGs

Sulfur Hexafluroride (SF6), C4F10

gas reclaiming unit

40 CFR Part 98, Mandatory Greenhouse Gas Reporting

HVAC &/or refrigerants

 

(various locations throughout facility)

ODSs

R-11, R-12, R-410A

EPA-certified maintenance mechanics for charged refrigerants maintenance

40 CFR Part 82, Protection of Stratospheric Ozone

 

40 CFR Part 82, Subpart G, Significant New Alternatives Policy (SNAP)

Emergency generators

 

(various locations throughout facility)

VOCs, NOx, CO, SO2, PM

Gasoline, Diesel

internal compliance requirements for using generators for emergency use only and limiting usage to < 500 hr/year

40 CFR Part 82, Protection of Stratospheric Ozone

 

9VAC5-80, Permits for Stationary Sources

Other fuel-burning equipment and gas-fired boilers

VOCs, NOx, SOx, CO, PM

Diesel fuel, Natural gas

-    digital monitoring system to inform system owner of operational status

-    annual preventative maintenance

40 CFR Part 82, Protection of Stratospheric Ozone

 

9VAC5-60, Hazardous Air Pollutants Sources

Demolition activities

 

(any expansion areas throughout facility)

HAPs

Asbestos, Lead

abatement process for proper removal prior to disturbance

40 CFR Part 61, National Emission Standards for Hazardous Air Pollutants (NESHAPs)

 

9VAC5-60, Hazardous Air Pollutants Sources

Radionuclides from accelerator enclosures

HAPs

H-3, N-13, Be-7, C-11, O-15, Cl-38, CL-39

-  ALARA

-  RadCon monitoring

-  NESHAP reporting

40 CFR Part 61, National Emission Standards for Hazardous Air Pollutants (NESHAPs)

Solvent, coating, and

spray paint use

VOC, HAP

Methanol, Hexane, Acetone, Butane, Propane

pollution prevention practices to reduce overspray emissions

40 CFR Part 82, Protection of Stratospheric Ozone

 

40 CFR Part 61, National Emission Standards for Hazardous Air Pollutants (NESHAPs)

 

9VAC5-60, Hazardous Air Pollutants Sources

4.1           Emission Source Review

Note:  This is how TJNAF stays abreast of our current emission inventory in order to identify and satisfy regulatory requirements.

4.1.1    periodic review of existing inventory as listed in the above table

4.1.2    review of new projects, experiments, etc. as noted in ES&H Manual Chapter 8010, Environmental Planning and Review.

4.2           Maintenance of Test Lab Scrubbers

Three scrubbers are located in the Test Lab Addition (TLA) mezzanine area to treat exhaust generated by activities occurring in the Production Chem Room, R&D Chem Room, and Clean Room. Annual maintenance activities are conducted by FM&L to ensure proper operations. If required, as acid processing demand increases, caustic can be injected into the scrubber system recirculated water basins to improve scrubber acid removal.

4.3           Greenhouse Gases

Greenhouse gases (GHGs) absorb infrared radiation and emit heat into the atmosphere. The primary GHGs in Earth's atmosphere are water vapor, carbon dioxide, methane, nitrous oxide, and ozone. Sulfur hexafluoride (SF6) is a GHG used in experimental processes at Jefferson Lab. The Lab’s minimum requirements are consistent with the objectives of and DOE O 232.2A Chg1 (MinChg), Occurrence Reporting and Processing of Operations Information.

 

Sulfur hexafluoride user responsibilities include:

·       maintaining records of all SF6 purchases.

·       establishing and maintaining an accurate inventory of SF6.

·       establishing and implementing an operating procedure(s) documenting equipment capacity and detailing a program for leak detection, repair, and methods to recover and store SF6 when appropriate.

·       identification and use of an authorized SF6 dealer &/or recycler when appropriate.

·       reporting any releases greater than 25 pounds to the ES&H Reporting Officer (x7712).

·       reporting annual inventory to the Site Sustainability Manager.

4.4           Ozone Depleting Substances

Regulatory requirements exist for ozone depleting substances (ODS’) that may be applicable to Jefferson Lab operations, including refrigerants such as R-11 and R-12 that are used for cooling systems on site. There are special requirements (per Section 608 of the CAA) for handling, recycling, and disposing of these refrigerants. They include appropriate EPA training certification for technicians servicing air conditioning and refrigeration equipment; repair of leaking industrial and commercial refrigeration equipment; and, maintaining service records documenting the date, refrigerant charge amount, and disposal of equipment. 

TJNAF further provides annual reporting to DOE on the:

·       amount of ODS’ or High Global Warming potential HFCs used onsite per FAR Clause 52.223-11; and,

·       maintenance, service, repair or disposal of refrigerant equipment per FAR Clause 52.223-12.

In order to comply with Section 612 of the Clean Air Act, TJNAF references the Significant New Alternatives Policy (SNAP) program as described in 40 CFR Part 82, Subpart G.  The SNAP program’s regulations provide listings of alternative substitutes for ODS’ when upgrades or replacements are required for onsite refrigerants-containing equipment.

4.5           Radioactive Air Emissions

Radionuclide emissions are regulated under 40 CFR Part 61 Subpart H, National Emission Standards for Emissions of Radionuclides Other than Radon from Department of Energy Facilities. Included in these regulations are requirements for emission monitoring and testing, emission compliance and reporting, and routine recordkeeping of activities associated with potential emissions as related to the annual effective dose equivalent (EDE) to the public.    

Airborne emissions of radionuclides at Jefferson Lab are far below the regulatory limit of 10 mrem/yr to the maximally exposed member of the public. In addition, no emission point at the Lab exceeds the regulatory threshold for a continuous monitoring program of 0.1 mrem/yr. Confirmatory monitoring is conducted and required annual reporting under 40 CFR 61 is performed based on very conservative emissions estimates. The procedure used to calculate this emission is maintained by the Radiation Control Department.

4.6           Emergency Generator Usage

The Virginia DEQ regulates emergency and non-emergency generators, under 9VAC5-80 Part II Article 6, Permits for New & Modified Stationary Sources. Under these regulations, emergency generators are classified as stationary emissions sources that are used for emergency use only and do not individually exceed 500 hours of operation per year at a single stationary source. These hours of operations are tracked to ensure that Jefferson Lab does not exceed 500 hours per year, thus maintaining status as emergency generators.

5.0          Revision History

rev

summary

date

2.0

updated:

- Note: in 3.0; header & footers; hyperlinks, bullets, etc. throughout

- Revision Summary to this format, Revision History

added: NEXT to REVIEW DATE; and, REVIEW CYCLE to footer

per IA Report #121899 and Corrective Action Plan #123882, the following were added or updated

- Table in 4.0, SNAP program description

- 4.4, Ozone Depleting Substances

07.01.2022

1.0

periodic review, no changes necessary per TPOC

10.27.2020

0.0

initial content

10.27.2017

 

 

 

ISSUING AUTHORITY

TECHNICAL POINT-OF-CONTACT

APPROVAL DATE

NEXT REVIEW DATE

REVIEW CYCLE

rev

 

 

ES&H Division

Scott Conley

10.27.2017

07.01.2025

3 years

2.0

 

This document is controlled as an online file.  It may be printed but the print copy is not a controlled document. 

It is the user’s responsibility to ensure that the document is the same revision as the current online file.  This copy was printed on 7/1/2022.