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

Oak Ridge Reservation
three boilers. A pair of regular non-redundant backup monitors were completed. The reports were
submitted on April 15, 2009, to TDEC and EPA.
In addition, the NOx analyzers are calibrated daily under the control of a data logger at a specified
time during normal operation (as recorded by the data logger internal clock). On a weekly basis, the
subcontractor personnel review the continuous emission monitoring system (CEMS) data reports that are
generated on a daily basis by the data acquisition and handling system, including calibration error reports
and data summary reports. On a daily basis, subcontractor personnel monitor the CEMS performance via
telephone modem. Linearity checks on the NOx analyzers are conducted on a quarterly basis. The linearity
checks are conducted while the unit is combusting fuel at typical duct temperature and pressure. The
linearity checks for NOx analyzers were conducted in April and August 2009, in accordance with
40 CFR 75. The linearity tests are submitted with the NOx electronic reports.
4.4.1.6 Hazardous Air Pollutants (Nonradiological)
Beryllium emissions from machine shops are regulated under a state-issued permit and are subject to
a limit of 10 g per 24 h. Compliance is demonstrated through a one-time stack test and through
monitoring of control device operations. Hydrogen fluoride is used at one emission source, and emissions
are controlled through the use of scrubber systems. Methanol is released as fugitive emissions (e.g., pump
and valve leaks) as part of the brine/methanol system. Methanol is subject to state air permit
requirements; however, due to the nature of its release (fugitive emissions only), there are no specific
emission limits or mandated controls. Mercury is a significant legacy contaminant at the Y-12 Complex,
and cleanup is being addressed under the environmental remediation program. Like methanol emissions,
mercury air emissions from legacy sources are fugitive in nature and therefore are not subject to specific
air emission limits or controls. On-site monitoring of mercury is conducted and is discussed under
Sect. 4.4.2, Ambient Air.
Y-12 Steam Plant emissions, due to the combustion of coal, contain hazardous air pollutants such as
mercury, hydrogen chloride, and other metals and gaseous hazardous air pollutants. In 2007 the EPA
vacated a proposed MACT, which was intended to minimize hazardous air pollution emissions. The Y-12
Steam Plant would have become subject to certain elements of the new rule effective in 2007 had the rule
not been vacated. It is anticipated at this time that the new natural-gas-fired steam plant will be on-line in
2010 and that coal will no longer be combusted, prior to the rule becoming effective. In 2007, a case-bycase
MACT review was conducted as part of the construction permitting process for the Y-12
replacement steam plant. Specific conditions aimed at minimizing hazardous air pollutant emission from
the new steam plant will be incorporated into the operating permit for the new source.
Unplanned releases of hazardous air pollutants are regulated through the Risk Management Planning
regulations. Y-12 Complex personnel have determined that there are no processes or facilities containing
inventories of chemicals in quantities exceeding thresholds specified in rules pursuant to Clean Air Act,
Title III, Sect.112(r), “Prevention of Accidental Releases.” Therefore, the Y-12 Complex is not subject to
that rule. Procedures are in place to continually review new processes and/or process changes against the
rule thresholds.
4.4.2 Ambient Air
To understand the complete picture of ambient air monitoring in and around the Y-12 Complex, data
from monitoring conducted on and off site specifically for Y-12, DOE reservation-wide monitoring, and
on-site and off-site monitoring conducted by TDEC personnel must be considered. There are no federal
regulations, state regulations, or DOE orders that require ambient air monitoring within the Y-12
Complex boundary; however, on-site ambient air monitoring for mercury and radionuclides is conducted
as a best management practice. With the reduction of plant operations and improved emission and
administrative controls, levels of measured pollutants have decreased significantly during the past several
years. In addition, major processes that result in emission of enriched and depleted uranium are equipped
with stack samplers that have been reviewed and approved by EPA to meet requirements of the NESHAP
regulations.
4-40 The Y-12 National Security Complex