|
TITLE |
||
|
|||
DOCUMENT ID |
8030 Air
Quality |
||
|
|||
1.0
Purpose
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 |
10.27.2017 |
07.01.2025 |
3 years |
2.0 |
|