EPS-20 Air Quality Management

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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
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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.
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EPS-20 Air Quality Management
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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).
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