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

Annual Site Environmental Report
consists of tasks such as continuous stack sampling, one-time stack sampling, and monitoring the
operation of control devices. Examples of continuous stack sampling are the radiological stack monitoring
systems on numerous sources throughout the complex, continuous NOx monitors on the steam plant, and
continuous opacity monitors on the steam plant. The Y-12 Complex site-wide permit requires quarterly
and semiannual reports. In addition, two major annual reports are required. One report is the overall ORR
radiological NESHAP report (CFR 2009a), which includes specific information regarding Y-12 Complex
emissions; the second is an annual Title V compliance certification report indicating compliance status
with all conditions of the permit.
4.4.1.1 Generally Applicable Permit Requirements
The Y-12 Complex, like many industrial sites, has a number of generally applicable requirements that
require management and control. Asbestos, ozone-depleting substances, and fugitive particulate emissions
are notable examples.
Control of Asbestos
The Y-12 Complex has numerous buildings and equipment that contain asbestos-containing
materials. The compliance program for management of removal and disposal of asbestos-containing
materials includes demolition and renovation notifications to TDEC and inspections, monitoring, and
prescribed work practices for abatement and disposal of asbestos materials. There was one reportable
release of asbestos in 2009, when an acetylene cylinder was inadvertently punctured while performing
site cleanup activities and operating heavy equipment at the 9720-58 yard (see Sect. 4.3.9.4). Corrective
actions were implemented, and the area cleared of asbestos with approval from the Supervisor of the
Asbestos Abatement Activity for resumption of normal activities. There was no impact to the
environment.
Stratospheric Ozone Protection
Y/TS-1880, Y-12 Complex Ozone Depleting Substances (ODS) Phase-Out and Management Plan
(B&W Y-12 2009a), provides a complete discussion of requirements and compliance activities at the
Y-12 Complex. ODS reductions are based on the DOE Order 450.1A (DOE 2008a) objective to phase out
as equipment reaches life expectance, equipment repairs are no longer cost-effective, or viable solvent
replacements are identified. Past ODS reduction initiatives began in the early 1980s and focused on
Class I ODS usage in refrigerants and solvent cleaning operations. Only one small chiller remains at the
Y-12 Complex which contains Class I ODS. This system has a 181-kg (400-lb) charge of refrigerant and
was manufactured in 1992. If it is determined to be economically practicable, this system will be
retrofitted in accordance with the DOE 2010 implementation goal.
Y-12 Complex initiatives in support of the DOE objectives have also involved elimination of solvents
in cleaning processes. Operations personnel developed and implemented changes in one process which
reduced the amount of ODS solvent emissions by up to 8,891 kg (19,600 lb) each year. Evaluation of
ODS reduction opportunities continue for another solvent cleaning operation. Future actions related to
this process will be dependent on ongoing efforts to identify a safe and viable replacement chemical or to
identify practical and cost-effective modifications to process equipment.
Any Class I and Class II substitutions are made in accordance with EPA’s Significant New
Alternatives Program (SNAP). Y-12 Complex personnel are notified as EPA issues regulations detailing
SNAP replacement chemicals which may be applicable to plant operations. In order to prevent ODS from
coming on-site, procurement documents are written to ensure that no additional equipment or processes
using Class I ODS are brought onsite, and Class II ODS usage is limited wherever possible.
Infrastructure reduction activities also led to the reduction of ODS materials on site. All refrigerants
and solvents must be removed from equipment prior to disposal. Recovered ODS are typically
recycled/reused in other equipment in the Y-12 Complex. However, Class I ODS deemed excess must be
transferred to Defense Logistics Agency as needed. Remaining ODS are offered to other DOE sites or
government agencies, sold, or properly disposed if not useable.
The Y-12 National Security Complex 4-35