DOE/ORO/2327 Oak Ridge Reservation Annual Site Environmental ...

Oak Ridge Reservation
air emissions at Y-12. Major requirements included in that section include the National Emission
Standards for Hazardous Air Pollutants for Radionuclides (Rad NESHAPs) requirements and the
numerous requirements associated with emissions of criteria pollutants and other hazardous air pollutants
(nonradiological). In addition, a number of sources that are exempt from permitting requirements under
state rules but subject to listing on Title V permit application are documented, and information about
them is available upon request from the state.
Ambient air monitoring, while not specifically required by any permit condition, is conducted at Y-12
to satisfy DOE order requirements, as a best management practice and/or to provide evidence of sufficient
programmatic control of certain emissions. Ambient air monitoring conducted specifically for Y-12 (i.e.,
mercury monitoring) is supplemented by additional monitoring conducted for the ORR and by both onsite
and off-site monitoring conducted by TDEC. In addition, the overall effectiveness of the Clean Air
Act compliance program is ensured by internal audits and external audits, such as the annual inspection
conducted by state of Tennessee personnel.
4.4.1 Construction and Operating Permits
In 2009, Y-12 Complex had only one construction air permit. A construction permit for the
replacement steam plant continued in 2009.
The DOE/NNSA and Y-12 Title V permits, currently two permits with an outstanding request to
combine them into one permit, include 37 air emission sources and more than 100 air emission points. All
remaining emission sources are categorized as insignificant and exempt from permitting. The Tennessee
Air Pollution Control Board issued a minor modification to the Title V Major Source Operating Permit
554701 on April 5, 2009. The minor modification was to align permit conditions with site transformation
activities. Permit change requests still pending at the end of 2009 include
• a request to convert one construction permit to an operating permit;
• a request to combine permit 554594 (which only has one emission source) into the existing Y-12 sitewide
permit;
• a request to add the new steam plant to the operating permit; and
• a request to add Fuel Station Stage 1 emission control requirements to the permit.
The Y-12 Complex major source (Title V) operating air permit renewal application was prepared and
hand-delivered to the TDEC personnel in April 2009. As part of the permit application renewal, it was
requested that TDEC combine Air Permit 554594 into Air Permit 554701 followed by cancellation of Air
Permit 554594. The complete permit application consists of four volumes. The complete, unedited
application consists of Volumes 1, 2, 3.2, and 4.3. Volumes 3.1, 4.1, and 4.2, which are edited for
classification reasons, were provided to the TDEC for their review and approval. Any classified
information is held on site at the Y-12 National Security Complex for the appropriately Q-cleared TDEC
personnel to review as needed.
Permit administration fees in excess of $100,000 per year are paid to TDEC in support of the Title V
program. Y-12 has chosen to pay the fees based on a combination of actual emissions [steam plant,
methanol, solvent 140 volatile organic compound (VOC)] and allowable emissions (balance of plant). In
years when a detailed air emission inventory is not required to be compiled for Y-12 operations, the
emissions ledger compiled to support the annual fee payment is the most comprehensive presentation of
total site emissions. In 2009, emissions categorized as actual emissions totaled 2,697,704 kg
(2,973.71 tons), and emissions calculated by the allowable methodology totaled 756,365 kg (833.75 tons).
The total emissions fee paid was $139,736.57.
Demonstrating compliance with the conditions of air permits is a significant effort at the Y-12
Complex. Key elements of maintaining compliance are maintenance and operation of control devices,
monitoring, record-keeping, and reporting. High-efficiency particulate air (HEPA) filters, baghouses, and
scrubbers are control devices used at the Y-12 Complex. HEPA filters are found throughout the complex,
and in-place testing of HEPA filters to verify the integrity of the filters is routinely performed. Baghouses
and scrubbers are operated and maintained in accordance with source-specific procedures. Monitoring
4-34 The Y-12 National Security Complex