LA-13528-SRStatus Report

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Emissions Inventory Report Summary

Reporting Requirements for theNew Mexico Administrative Code, Title 20,Chapter 2, Part 73 (20 iVMAC 2.73) forCalendar Year 1997

Los AlamosNATIONAL LABORATORY

Los Alamos National ,hboratory is operated by fhe University of Cal#orniafor the United Stafes Deparfmenf of Energy under contracf W-740.5-ENG-36.

‘,

This report was prepared as an account of work sponsored by an agency of the United SfafesGovernment. Neither The Regents of theUniversity of California, the f.hzifedStafesGovernment nor any agency fhereoj nor any of fha”remployees,makes any warranty, expressor implied, or assumes any legal liabilityor responsibilityfor the accuracy, completeness, orWfI.dness of any information, apparafus, product, or process disclosed, or represents fhaf itsuse would nof infringe privately uwned rights. Refwence herein fo any spect$c commercialproducf, process, or service by fr-ademarne,fi-ademark,manufacturer, or otherwise, does nofnecessarily constifufe or imply ifs endorsement, recommendation, or favoring by The Regenfsof the University of Ca~t$ornia,the Unifed Sfates Government, or any agency thereof. Them“ewsand opinions of au fhors expressed herein do nof necessarily state or rej7ecffhoseofThe Regents of fhe University of California, theUnited Sfates Government, or any agencyfhereof. Los Alamos National Laboratory sfrongly supports academic freedom and aresearcher’s righf to publish; as an institution, however, the laborafoy does nof endorse theviewpoint of a publication or guarantee its technical correctness.

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LA-13528-SKStatus Report

Issued: January 1999

Emissions Irmentory Report Summary

Reporting Requiremenhfor theNew Mexico Administrative Code, Title 20,Chapter 2, Part 73 (20 NMAC 2.73) forCalendar Year 1997

Air Quality Group, ESH-17

Los AlamosNATIONAL LABORATORY

Los Alamos, New Mexico 87545

Table of Contents

1.0 Introduction ............................................................................................................................. 1

2.0 Emissions Inventory Reporting Requirements ........................................................................ 2

3.0 Content of Emissions Inventory Report .................................................................................. 2

4.0 Reported Sources and Methods for Emissions Estimates ........................................................ 2

4.1 Industrial Sources ................................................................................................................. 2

4.1.1 Industrial Source Emission Estimates ........................................................................... 3

4.2 Research and Development Activities .................................................................................. 3

4.2.1 VOC Emissions from R&D Activities ........................................................................... 4

4.3 Additional Permitted Sources ............................................................................................... 4

5.0 Reporting Exemptions .............................................................................................................. 4

6.0 Emissions Summary ................................................................................................................. 5

v

EMISSIONS INVENTORY REPORT SUMMARY

by

Air Quality Group, ESH-17

ABSTRACT

Los Alamos National Laboratory (the Laboratory) is subject toemissions reporting requirements for regulated air contaminantsunder Title 20 of the New Mexico Administrative Code, Chapter 2,Part 73, (20 NMAC 2.73), Notice of Intent and EmissionsInventory Requirements. The Laboratory has the potential to emit100 tons per year of suspended particulate matter (PM), nitrogenoxides (NOX), carbon monoxide (CO), and volatile organiccompounds (VOCS). For 1997, combustion products from theindustrial sources contributed the greatest amount of regulated airemissions from the Laboratory. Research and developmentactivities contributed the greatest amount of VOCS. Emissions ofberyllium and aluminum were reported for activities permittedunder 20 NMAC 2.72, Construction Permits.

1.0 INTRODUCTION

Los Alamos National Laboratory (the pollutant standards for both the State and Fed-Laboratory) has reported the regulated air eral Acts are not violated. The air contaminantspollutants generated from its operations since reported are total particulate (PM), carbonthe late 1980s when the requirement under Title monoxide (CO), nitrogen oxides (NOX), sulfur20 of the New Mexico Administrative Code, oxides (SOX), volatile organic compoundsChapter 2, Part 73, (20 NMAC 2.73) Notice of (VOCS), beryllium, and aluminum.Intent and Emissions Inventory Requirements,was first promulgated. The objective of thereporting requirement is to ensure that regulated

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2.0 EMISSIONS INVENTORYREPORTING REQUIREMENTS

Annual emissions reporting requirementsunder 20 NMAC 2.73 applies to any source thatemits, or has the potential to emit, 5 tons peryear or more of lead or lead compounds, or 100tons per year or more of suspended particulatematter in the size range of 10 microns or less

(PMIO), S0,, NOX,CO, or VOCS. Emissionsfrom units that emit more than 1 ton of lead or10 tons per year of the pollutants listed above aswell as emissions from permitted sources mustbe included in the report. On October 1, 1997,the emissions report requirements were revisedto include VOC emissions. This required theLaboratory to include emission estimates fromits Research and Development (R&D) opera-tions not previously covered under the 20NMAC 2.72 permitted sources.

3.0 CONTENT OF EMISSIONSINVENTORY REPORT

The information required in the reportincludes the following:

● The name, location, owner, and operator ofthe facility;

● Facility contact information;

Signed certification statements by a respon-sible facility official; andSpecific information for each emission pointsuch as stack and exhaust parameters; typeof control equipment with associated controlefficiencies; schedule of operation; annualprocess or fuel combustion rates; the fuelheat, sulfur, and ash content; and estimatedactual emissions.

4.0 REPORTED SOURCES ANDMETHODS FOR EMISSIONSESTIMATES

The Laboratory’s 1997 Emissions InventoryRequirements report included estimated actualemissions from industrial type sources such asthe power plants, the large boilers, the asphaltplant, and the water pump. In addition, VOCemissions from R&D and painting operationswere assessed and reported as appropriate. Theberyllium emissions were reported at permittedemission levels.

4.1 Industrial Sources

Power and boiler plant operations producesteam for heating and/or electricity when suffi-cient power from outside sources is not avail-able. The Asphalt Plant, pictured in Figure 1,

Figure 1. Asphalt Plant.

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produces small amounts of asphalt for roadrepairs in and around the Laboratory. Finally, anatural gas burning water pump is used to pumppotable water from underground wells. A list ofthe reported industrial sources, the locationwithin the Laboratory, and the unit identifica-tion is as follows:

● Technical Area (TA) 3 Power Plant;● TA-21 Power Plant;● Boilers:

TA-16, Plants 4, 5,6, and 13;TA-48-1 ;TA-53-365-l;TA-53-365-2;TA-55-6- 1;TA-55-6-2;TA-55-6-3;TA-55-6-4;

● Asphalt Plant; and● Water Pump at TA-54.

4.1.1 Industrial Source Emission Estimates

Emissions from the Laboratory’s industrialsources were estimated using fuel use, operatingrecords, and the appropriate emission factors.These sources are primarily operated on naturalgas.

Various methods and resources were used todetermine individual site emissions. The NOXemissions from the TA-3 Power Plant werecalculated using an emission factor obtainedfrom a stack test. A turbine from the mainPower Plant is pictured in Figure 2. The NOXand CO emission factors for the TA- 16 boilerswere calculated using data provided by themanufacturer. Emissions from the Asphalt Plantwere based on the 1306 tons of asphalt producedin 1997. The PM emissions from the asphaltplant were calculated using an emission factorobtained from a stack test. Emission factors forNOX, CO, and VOC emissions from the waterpump were obtained from the manufacturer.Emissions from fuel combustion equipmentwere based on the actual or estimated fuelconsumption. All other industrial source emis-sions were estimated using EnvironmentalProtection Agency (EPA) guidance documents.

4.2 Research and Development Activities

The majority of the Laboratory’s work isdevoted to R&D activities. These activities varyin size, chemicaJ use, and operating parameters.Furthermore, R&D activities occur at virtuallyall TAs within the Laboratory.

Figure 2. Turbine at the Main Power Plant.

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4.2.1 VOC Emissions from R&D Activities

VOCS are any compound of carbon, with theexception of specific chemicals, which partici-pates in atmospheric photochemical reactions.VOCS include commonly used chemicals suchas ethanol, methanol, and isopropyl alcohol.Chemical use and process information wereobtained for the VOCS that made up a largepercentage of the 1997 total from theLaboratory’s procurement records. Emissionswere refined based on the process data receivedfrom the various users. Those chemicals, whichhad multiple users and multiple processes, wereassumed to be 100% emitted as a conservativeestimate. Ten tons of VOC emissions wereestimated based on chemical procurementrecords. Figure 3 shows an example of chemi-cals that are tracked by the procurement records.

4.3 Additional Permitted Sources

Five sources are permitted under 20 NMAC2.72, Construction Permits. These sources areberyllium machining operations and are subjectto 40 CFR 61, Subpart C, National EmissionStandards for Beryllium. Emissions from these

sources were reported at permitted emissionlevels. Actual emissions monitored during initialcompliance stack tests are below these levels.

5.0 REPORTING EXEMPTIONS

As part of the evaluation of VOC emissionsfrom the Laboratory, painting activities wereconsidered. Painting activity information forcalendar year 1997 was gathered from thefollowing Laboratory databases:

Work Order Control (WOC) databasemaintained by Johnson Controls of NorthernNew Mexico (JCNNM);Just-In-Time (JIT);Local Vendor Agreement (LVA);Purchase order (PO); andAutomated Chemical Inventory System(ACIS).

The WOC database contained all JCNNMpaint jobs and associated descriptions for calen-dar year 1997. Two hundred and one jobs wereidentified as being paint related. By using thejob description field, a preliminary determina-

Figure 3. Gases ready for distribution within the Laboratory. The gases are tracked by theprocurement record keeping.

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tion was made as to whether the job was main-tenance related. Of the two hundred and onejobs, ten jobs required detailed interviews withthe respective paint supervisor. Of these tenjobs, nine were maintenance related and one didnot use paint at all.

The JIT, LVA, PO, and ACIS databasesystems were used to capture paint procurementrecords. Requesters of paint were identifiedfrom the records and interviewed to determinepaint usage. Figure 4 shows a paint booth at theLaboratory used exclusively for maintenancepainting.

A determination was made based on the datareceived from the various paint users that allpainting activities for 1997 were maintenancerelated and therefore were exempt from emis-sion reporting requirements. Emissions fromexempt activities are not required to appear onthe emissions inventory report. As specified inthe New Mexico Environment Department

(NMED) ‘List of Trivial Activities’, datedJanuary 10, 1996, these activities include thefollowing:

“Activities that occur strictlv for mainte-nance of~ rounds or buildings, including.” lawncare, pest control, grinding, cutting, welding,painting woodworking, sweeping, generalrepairs, janitorial activities, plumbing, re -tarring roofs, installing insulation, steamcleaning and water washing activities, andpaving of roads, parking lots and other areas. ”

6.0 EMISSIONS SUMMARY

The Laboratory’s reported emissions for1997 are summarized in Table 1. The largestsources of regulated pollutants emitted at theLaboratory were combustion products fromindustrial sources. Three sources (Stack No.005,009, and O12) listed on the forms providedby the state have never been built or operated.

Figure 4. Paint Booth.

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m Table 1. Summary of Estimated Emissions for

Emission SourcesSfack A/o.

Industrial Sources002 Edgemoor BLRS 3EA TA-3-22003 Steam Plant TA-16-Bldg 540004 Industrial BLRS 3 TA-21 -357

005 TD Site Not Operating Stack

012 Solid Waste Fired Boiler

013 Asphalt Rotary Dryer TA-3-73014 Pump Engine

Other Permitted Sources001 BE Shop, TA-3, Bldg 39, Room 16

006 BE Machining TA-35, Bldg 213

007 BE Machining TA-3, Bldg 141

008 BE Machining TA-3, Bldg 102

009 BE Shop, TA-3-35 Not Built Stack

010 BE Cutting and Bead Dressing

011 Metallography

Subtotal in lb/yr:Subtotal in ton/yr:

A/on-Exemd BoilersBoiler Emission in lb/yr:Boiler Emission in ton/yr:

R&D EmissionsEmissions in lb/yr:Emissions in ton/yr:

1997 Emission Tots/s

1997 Emissions Inventory Report (20 NMAC 2.73)

Estimated Actual Emissions (lb/year)Aluminum Beryllium

0.00.00.00.0

0.00.00.0

0.0

0.0

0.0

0.0

0.0

0.004

0.00.0040.000002

N/ANIA

NIANIA

Total Estimated Emissions in lb/yr: 0.004Total Estimated Emissions in ton/yr: 0.000002

0.00.00.00.0

0.00.00.0

0.008

0.0008

0.0004

0.00014

0.0

0.0042

0.0030.01650.0000004

NIANIA

NIANIA

0.01650.0000004

Nox—

1132990.0

8132

0.0

0.0

3341282

0.0

0.0

0.0

0.0

0.0

0.0

0,0162746

81

114385.8

NIANIA

17418387.1

=X

4170.0

35

0,0

0,0

6.516.03

0.0

0.0

0.0

0.0

0.0

0.0

0.0

4750.2

980.05

N/ANIA

5730.3

34750.0

813

0.0

0.0

9125

278030.0

2033

0.0

0.0

44413210

0.008 0.0

0,0008 0.0

0.0004 0.0

0.00014 0.0

0.0 0.0

0.0082 0.0

0.003 0.0

4404 434902.2 22

1908 4488

0.95 2.2

NIA NIANIA NIA

6312 479793.2 24

J&3’&

9730.0

163

0.0

0.0

22826

0.0

0.0

0.0

0.0

0.0

0<0

0.01984

0.99

8460.4

1999710

2282711

Therefore, these sources are listed with zeroemissions. Emissions of beryllium and alumi-num are reported for those sources that haveemission limits required by 20 NMAC 2.72,Construction Permits. The beryllium and alumi-num emissions are also reported under the PMemissions. Some pollutant emissions are notgenerated or applicable to the boilers operationand the research and development activities.

Figure 5 provides a comparison between1995 and 1997 emissions reported to NMED.

The emissions decreased over the two-yearperiod. The comparison cannot be used for thequantity of SOX and VOC emissions that theLaboratory reported to NMED in 1997 becauseS0, emissions and VOC emissions from R&Dactivities were not reported in 1995.

Figure 6 shows the criteria pollutants bysource. The main Power Plant contributes thegreatest amount of NOX, SOX, PM, and COemissions. R&D activities contribute the mostVOC emissions.

Total Emissions

El❑ 1995

In 1997

Criteria Pollutants Voc

Figure 5. Criteria Pollutant Emissions Generated in 1995 and 1997

Total Emissions

o.o+ia

Criteria Pollutant Emission Sources

❑SOX ❑PM ❑CO ❑VOC~NOx

Figure 6. Criteria Pollutant Emissions by Source in 1997.

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Los AlamosNATIONAL LABORATORY

Los Aiamos, New Mexico 87545