EP Supplement EPS-20 Air Quality Management Thomas Jefferson National Accelerator Facility EPS-20 Air Quality Management Introduction T his chapter summarizes Jefferson Lab’s air quality management program and includes an overview of the federal and state air quality regulatory requirements, the specific air pollutant emission sources found at Jefferson Lab, and a discussion on air pollution minimization. Jefferson Lab satisfies all air pollution regulatory requirements and maintains its policy of minimizing emissions of air pollutants to the outdoor environment. This chapter focuses primarily on air pollution sources at Jefferson Lab that have the potential to impact the outdoor environment and briefly discusses indoor air quality and industrial hygiene related issues such as asbestos. However, more detailed information on industrial hygiene and indoor air quality issues can be found in the 6600 series chapters of the Jefferson Lab ESH&Q Manual. Respiratory protection is specifically addressed in ESH&Q Manual Chapter 6630 Respiratory Protection. Under the Lab’s EMS, the Jefferson Lab environmental aspects that are addressed are: • Ionizing radiation - air activation • Air emissions - fugitive(e.g., fume hood and boiler emissions) • Air emissions - hazardous air pollutants (radionuclides) • Air emissions - ozone depleting substances (e.g., chlorofluorocarbons and halon) • Air emissions - particulates (e.g., dust and lead) • Air emissions - volatile organic compounds (e.g., diesel fuel and paints) Appendices ● EPS 20-T1 Ozone Depleting Substances and Jefferson Lab ● EPS 20-R1 Air Quality Regulatory Information ● EPS 20-R2 Air Emissions Inventory EPS20AirQuality.fm rev. August 26, 2005 EPS-20 Page 1 of 11 EP Supplement Thomas Jefferson National Accelerator Facility EPS-20 Air Quality Management Key Terms Chapter 6710 Environmental Protection Program contains descriptions of relevant laws, regulations, standards, terms, and agencies that are fundamental to the environmental protection (EP) program. Many of these laws and standards apply to air quality and are referenced herein. The following air quality specific terms and acronyms are used in this chapter. actual emissions The measured or calculated rate of air pollutants discharged from a given emissions source into the ambient air, typically reported in tons per year. air pollutant Any airborne substance that may be harmful to human, animal, or plant life. asbestos Any of several silicate minerals including chrysotile, crocidolite, and amosite that separate into long flexible fibers suitable for use as a noncombustible, nonconducting, and chemically resistant material. Asbestos is known as a human carcinogen and is considered a hazardous air pollutant. carbon monoxide (CO) A colorless, odorless, tasteless gas which can cause dizziness, unconsciousness, or even death by reducing the blood’s ability to carry oxygen. CO is produced from the incomplete combustion of carbon-based fuels including oil, gasoline, and wood. chlorofluorocarbons (CFCs) Substances which are used as refrigerants, solvents, aerosol propellants, and foaming agents, that are capable of depleting stratospheric ozone. criteria pollutant A group of common air pollutants which are regulated based on health and/or environmental effects. These include carbon monoxide (CO), nitrogen oxides (NOx), ozone (regulated as VOCs), particulate matter, sulfur dioxide (SO2), and lead. emissions unit Any source, such as production or process equipment, fuel burning equipment, or a storage tank that has the potential to emit air pollutants. fugitive emissions Air pollutants which are emitted directly to the atmosphere, not through a well-defined stack or vent. halons CFCs containing one or more bromine atoms which are commercially used in fire extinguishers and also sold under different refrigerant trade names such as Freon. Hazardous Air Pollutant (HAP) CAAA listed chemicals that present or may present a health threat or adverse environmental effects (40 CFR 61). hydrocarbons Substances whose molecules contain only hydrogen and carbon atoms. These compounds are emitted primarily from the partial combustion of fuels such as gasoline. maintenance area Any geographic region of the United States previously designated as a nonattainment area and subsequently redesignated to attainment subject to the requirement to develop a maintenance plan and designated as such in 9 VAC 5-20-203. EPS-20 Page 2 of 11 rev. August 26, 2005 EPS20AirQuality.fm EP Supplement EPS-20 Air Quality Management Thomas Jefferson National Accelerator Facility National Ambient Air Quality Standards (NAAQS) Standards in 40 CFR 50 which address concentrations of common pollutants in the atmosphere. These standards cover the six criteria pollutants and define levels which may endanger public health or welfare. National Emission Standards for Hazardous Air Pollutants (NESHAP) Standards in 40 CFR which specifically address and impose requirements on sources which emit certain hazardous air pollutants. nitrogen oxides (NOx) [mainly nitric oxide (NO) and nitrogen dioxide (NO2)] These compounds are formed when nitrogen and oxygen from the air are combined under high temperature conditions during the combustion of various types of fuels. A variety of nitrogen oxides interact with volatile organic compounds to form ozone and other photochemical oxidants. Nitrogen oxides also contribute to formation of acidic compounds that can harm plants and animals through acid rain. nonattainment area A geographic area in which the level of a particular criteria pollutant or pollutants is higher than the level allowed by a National Ambient Air Quality Standard. ozone (O3) A principal component of smog. Low-altitude ozone is produced by a chemical reaction between nitrogen oxides and volatile organic compounds in the presence of oxygen and sunlight. Photochemical oxidants such as ozone impair breathing; irritate eyes, nose, and throat; reduce visibility; and, damage vegetation and many man-made materials. Acronyms CAAA The Clean Air Act Amendments of 1990 DEQ ozone depleting substance (ODS) These chemicals are believed to deplete ozone in the earth’s upper atmosphere (stratosphere) and may contribute to the formation of ozone holes. Ozone-depleting substances include CFCs and HCFCs. particulates A loose category which includes a wide range of solid or liquid airborne particles which are typically emitted during combustion activities or from grinding Commonwealth of Virginia Department materials. At Jefferson Lab, airborne particulates can become activated during of Environmental accelerator operations. Quality potential emissions The rate (typically reported in tons per year) at which a given emission unit is capable of releasing air pollutants to the atmosphere based on operating 8,760 hours per year (24 hours per day, 7 days per week, 52 weeks per year) HCFC at the maximum rated capacity. hydrochlorofluoroca EPA Environmental Protection Agency rbon MACT Maximum Achievable Control Technology SO2 sulfur dioxide TLV Threshold Limit Value sulfur oxides Primarily sulfur dioxide (SO2) with some sulfur trioxide (SO3), emitted when fossil fuels containing sulfur impurities are burned. These compounds are especially dangerous when combined with particulates. Volatile Organic Compound (VOC) Any non-methane hydrocarbon which participates in photochemical reactions to form ozone in the lower regions of the atmosphere. (The CAAA specify VOC and fugitive emission controls.) Refer to Appendix 6710-R1 Environmental Laws and Regulations for law and regulation descriptions. EPS20AirQuality.fm rev. August 26, 2005 EPS-20 Page 3 of 11 EP Supplement EPS-20 Air Quality Management Thomas Jefferson National Accelerator Facility Hazard Avoidance To minimize emissions of air pollutants to the workplace and the environment: ❖ Use non-polluting materials whenever possible. ❖ Use solvents that do not contain VOCs or, if necessary, use the lowest possible quantity. ❖ Keep solvent storage containers closed when not in use. ❖ Inspect and seal suspected leaks around refueling couplings, valves, and nozzles. ❖ Report visible leaks or unusual smoke and equipment malfunctions to Facilities Management, ext. 4444. ❖ Use air conditioning and refrigeration subcontractors that are certified in current refrigerant recycling techniques. ❖ Follow the guidance in Chapters 6680 Lead Handling and 6681 Asbestos Management when working on or near lead or asbestos-containing materials. EPS-20 Page 4 of 11 rev. August 26, 2005 EPS20AirQuality.fm EP Supplement EPS-20 Air Quality Management Thomas Jefferson National Accelerator Facility Responsibilities Chapter 6710 Environmental Protection Program summarizes staff EP responsibilities. The following responsibilities apply specifically to the air quality management program’s goals and objectives. Supervisors/Sponsors/SOTRs ❖ Minimize the use of CFCs, VOC-containing solvents, and products containing hazardous air pollutants (see Appendix EPS 20-R2 Air Emissions Inventory). ❖ Work with ESH&Q staff on issues related to air quality, including the development, implementation, and documentation of new operating procedures to minimize the release of air pollutants. ❖ Ensure that all work involving non-cryogenic refrigeration or air conditioning equipment is handled through Facilities Management. ESH&Q Staff ❖ Support line management by monitoring the implementation of the air quality management program in operations in your area of responsibility. Facilities Management Director ❖ Coordinate all work involving air conditioning and (non-cryogenic) refrigeration systems and ensure that all procedures are in accordance with Lab policies. ❖ Monitor and inspect equipment for potential hazards or conditions that could result in emissions of air pollutants. Correct conditions or change operations to prevent emissions and notify the appropriate division ESH&Q officer of significant problems. ❖ Perform emission monitoring and provide data annually to ESH&Q Reporting. ❖ Review and authorize any purchases involving CFC-related equipment or products. Division ESH&Q Officers ❖ Provide support to ESH&Q staff in implementing air quality-related policies and programs and ensure that activities which could threaten one’s health or air quality are stopped or corrected. ❖ Assist ESH&Q Reporting in evaluating regulatory requirements and inform ESH&Q Reporting promptly of any significant emission episode. RadCon Manager ❖ Establish procedures to minimize radionuclide emissions to the environment. ❖ Monitor for radionuclide emissions and provide information annually to the EPA and to ESH&Q Reporting. ESH&Q Reporting Manager ❖ Coordinate Jefferson Lab’s air quality management program and review the adequacy of actions taken to demonstrate compliance with air pollution regulatory requirements. EPS20AirQuality.fm rev. August 26, 2005 EPS-20 Page 5 of 11 EP Supplement Thomas Jefferson National Accelerator Facility EPS-20 Air Quality Management Qualifications Air conditioning/refrigeration equipment EPA-qualified technicians may service or repair the air conditioning and non-cryogenic refrigeration systems at Jefferson Lab. To limit emissions of ozone depleting substances, these certified technicians use approved refrigerant capturing and recycling equipment. Facilities Management shall ensure that all workers providing such services are certified. Note: Facilities Management will arrange for a qualified technician to do work anywhere on-site. Asbestos removal Only licensed personnel may perform renovation or repair work on a Jefferson Lab structure or piping system containing asbestos. Approved procedures are to be followed to prevent the release of asbestos to the ambient air. The Asbestos Program Manager shall ensure that training requirements are met. See Chapter 6681 Asbestos Management. EPS-20 Page 6 of 11 rev. August 26, 2005 EPS20AirQuality.fm EP Supplement EPS-20 Air Quality Management Thomas Jefferson National Accelerator Facility Program Summary Regulatory Programs The CAAA provide a comprehensive regulatory framework to improve air quality throughout the United States. In Virginia, the DEQ is responsible for regulating sources of air pollution and implementing the CAAA, but this could change in the future. The ESH&Q Reporting Manager reviews regulatory requirements periodically for applicability. Emissions of radionuclides, which are considered HAPs under Title III of the CAAA, are regulated by the federal EPA. Though airborne emissions of radionuclides are well below the regulatory threshold of 10 mrem/yr, annual reporting under 40 CFR 61 is performed. (For more information refer to Chapter 6315 Environmental Monitoring of Ionizing Radiation.) RadCon manages the airborne emission program. The production of ozone-depleting substances (ODSs) is being phased-out under Title VI of the CAAA. Small amounts of R-12 (CFC-12) are used in experimental equipment located in the end stations and portable halon fire suppression systems are present in each hall. (They are only to be used in an emergency.) Because CFC production is being phased out, Jefferson Lab must use suitable alternative materials. ESH&Q staff continue to assist line management in this effort. Contact ESH&Q Reporting (ext. 7308) or the Jefferson Lab Industrial Hygienist (ext. 7039) for additional information on these air quality regulatory issues. Jefferson Lab Air Emission Minimization Program “Environmentally friendly” substances are used where possible to minimize emissions of air pollutants to the atmosphere. These substances shall be considered as replacements for more polluting materials used in operations which generate air emissions. ESH&Q staff can assist in making informed selections. The ESH&Q Reporting Manager compiles emission rates periodically, provides requisite reports, proposes alternatives, and serves as a resource for additional information on regulatory issues. Methanol represents a significant source of releases. Look for substitutes and use vapor recovery as described in Appendix EPS 20-T1 Ozone-Depleting Substances and Jefferson Lab. EPS20AirQuality.fm rev. August 26, 2005 EPS-20 Page 7 of 11 EP Supplement EPS-20 Air Quality Management Thomas Jefferson National Accelerator Facility Air Pollution Emission Sources The following pieces of equipment or activities at Jefferson Lab have the potential to emit the air pollutants noted. Table 1: Air Pollution Emission Sources Emission Sources Air Pollutant(s) Chemicals/Compounds in use Fuel burning equipment, Natural gas boilers Particulates, CO, NOx, SO2, VOC Diesel Fuel, Natural Gas Solvent/coating/spray paint use VOC, HAP Methanol, Hexane Niobium cavity acid bath NOx Nitric acid, Hydrofluoric acid Cavity cleansing (Electropolish Cabinet) VOC, HAP, Hydrogen Isopropyl Alcohol, Methanol Experimental equipment ODSs R-12, Sulfur Hexafluoride Air conditioning/ Refrigeration equipment ODSs R-11, R-12 Accelerator operations Radionuclide emissions Maintenance or demolition activity resulting in a release HAP Emergency generators NOx Lawn care equipment Particulates, VOCs, HC, NOx, CO, CO2 Gasoline Asbestos, Lead CO: Carbon monoxideNOx:Nitrogen oxides HAP: Hazardous Air PollutantSO2:Sulfur dioxide HC: HydrocarbonVOC: Volatile Organic Compound An air emissions inventory has been completed for Jefferson Lab. Refer to Appendix EPS 20-R2 Air Emissions Inventory for more information. Boiler in Test Lab Newport News is part of the Hampton Roads Air Quality District which is currently a maintenance area (see Key Terms) for ozone. As such, permitted sources within the District must maintain particular criteria pollutant levels (in this case ozone) set forth by NAAQS. (Refer to Appendix EPS 20-R1 Air Quality Regulatory Information.) As Jefferson Lab’s air emissions are well below permit thresholds, no maintenance area actions are required of the Lab. EPS-20 Page 8 of 11 rev. August 26, 2005 EPS20AirQuality.fm EP Supplement EPS-20 Air Quality Management Thomas Jefferson National Accelerator Facility Specific Procedures Ozone Depleting Substances Air Conditioning and Refrigeration Equipment Releases of ODSs from the servicing of air conditioning and refrigeration equipment are minimized by using certified subcontractors who use required refrigerant recycling and recovery techniques to prevent emissions of CFCs and other ODSs. Fire Extinguishers/Halon Suppression Systems Releases of ozone depleting halons from fire extinguishers are prevented by removing halon-containing extinguishers from service when possible. The Physics Division has procured a number of wheeled 150 lb. halon units for experimental equipment fire suppression. These wheeled units are located in the end stations and in the Physics Storage Building. CFC Usage CFC usage on-site is prohibited except for approved uses. One exception is the CFCs used in physics experiments at Jefferson Lab. A 90 percent or greater CFC recovery process has been devised for the experimental chambers to minimize CFC emissions. Alternatives to CFCs, especially R-12, are being sought. CFC Reclamation All CFCs and HCFCs discharged during any maintenance activity must be reclaimed, and the work is to be performed by EPA-qualified persons under direction of the Facilities Management Director. ODS-related Procurement Business Services shall implement measures to eliminate the purchase of ODS-containing equipment. The Facilities Management Director shall approve the purchase of new ODS-containing equipment. Refer to Appendix EPS 20-T1 Ozone-Depleting Substances and Jefferson Lab for additional details. Asbestos Renovation or demolition Prior to any renovation or demolition activity involving asbestos, a formal inspection and project design are required. A licensed subcontractor or employee must perform this inspection in accordance with 40 CFR 763. As well, a licensed subcontractor must be used for the actual demolition work. Jefferson Lab’s Asbestos Program Manager (state licensed) at ext. 7531 shall be informed. See Chapter 6681 Asbestos Management for more information. Surveillance Periodic surveillance of asbestos-containing material is done to ensure these materials have not been disturbed. Work performed on any asbestos-containing material is done only under controlled conditions. EPS20AirQuality.fm rev. August 26, 2005 EPS-20 Page 9 of 11 EP Supplement Thomas Jefferson National Accelerator Facility EPS-20 Air Quality Management VOC Solvents/Coatings Selection Non-VOC containing solvents should be used whenever possible to minimize emissions of VOCs. ESH&Q staff can identify “environmentally friendly” alternatives. Use To minimize emissions of VOCs from solvents or paints: • Keep solvent and paint containers closed when not in use. • Minimize the use of solvents and paints. • Use solvents and paints under hoods which vent vapors through activated carbon filters to reduce VOC emissions. • Store solvent containers properly, inspect periodically for leaks, and replace any leaking containers or fittings immediately. Radionuclides Accelerator and experimental equipment operation Emissions or losses of radionuclides from the operation of the accelerator and experimental equipment are minimized by following established operating procedures. Radiation Control Group This group helps to limit emissions of radionuclides by providing guidance on accelerator component, systems design, and shielding to Lab management. Reporting under 40 CFR 61 Subpart H Radionuclide air emissions are reported annually (by calendar year) to the EPA. This reporting is done voluntarily, as the Lab is below reporting thresholds, to keep the EPA and DOE informed of our contribution to offsite exposure, which is negligible. Chapters 6310 Ionizing Radiation Protection and 6315 Environmental Monitoring of Ionizing Radiation provide more information on radionuclide emissions from accelerator operations and physics program experiments. EPS-20 Page 10 of 11 rev. August 26, 2005 EPS20AirQuality.fm EP Supplement EPS-20 Air Quality Management Thomas Jefferson National Accelerator Facility References EPS20AirQuality.fm • Air Quality related Work Smart Standard Hazard Issues - 044 Environmental – air emissions/nonrad - 045 Environmental – air emissions/rad - 047 Environmental – asbestos - 053 Environmental – ozone depleting substances • Air Quality Standards - The Clean Air Act and Amendments (42 U.S.C. 7401 et seq., Title III and IV) - 40 CFR 61, National Emission Standards for Hazardous Air Pollutants - 40 CFR 82, Protection of Stratospheric Ozone - 9 VAC 5-60-70, Designated Emission Standards, Subpart M - Asbestos • Other regulatory background information is available in ESH&Q Reporting. • Jefferson Lab’s Air Emission Inventory, dated July 14, 1995, by Environmental Resource Management, Inc. (ERM) • Information on “environmentally friendly” alternatives is available through the Safety Lab (ext. 7039) and ESH&Q Reporting (ext. 7308). rev. 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