Compliance with the Clean Air Act at Los Alamos National Laboratory

摘要

Los Alamos National Laboratory (LANL or Laboratory) is located in Los Alamos County, innorth-central New Mexico. The Laboratory's Ecology and Air Quality Group (ENV-EAQ) isresponsible for ensuring LANL's compliance with the Clean Air Act (CAA). A Laboratorystrategic goal is to improve the efficiency with which we achieve regulatory compliance andmanage risk to support operational excellence. Future compliance initiatives and protection of airquality should include an evaluation of operating permit conditions, the Laboratory'sEnvironmental Management System (EMS), and Record of Decision (ROD) for the Site-WideEnvironmental Impact Statement (SWEIS).The Laboratory is managed by Los Alamos National Security, LLC, (LANS) under a contractadministered by the National Nuclear Security Administration (NNSA) of the Department ofEnergy (DOE).Pursuant to federal CAA Amendments and Title 20 of New Mexico Administrative Code(NMAC), Chapter 2, Part 70, Operating Permits (20.2.70 NMAC), LANS is authorized tooperate LANL per the terms and conditions as defined in Operating Permit No. P100. Alllaboratory operations that have air emissions exceeding established regulatory levels are coveredas part of this permit. Implementing the Title V Operating permit requires increased recordkeeping, increased frequency of reporting, and an annual compliance certification. LANL is amajor source, based on the potential to emit, for nitrogen oxides (NOX), carbon monoxide (CO),and volatile organic compounds (VOCs). LANL reports annual emissions for sources included inthe operating permit. This permit program includes permit requirements for the NationalEmission Standards for Hazardous Air Pollutants (NESHAP) program and Radionuclides-NESHAP (Rad-NESHAP) program. The Laboratory also operates under the requirements of theBeryllium NESHAP program and the New Source Performance Standards (NSPS) program,which will not be discussed in this paper.A system is in place to manage environmental risks. In addition to leadership and managementprovided by the staff of ENV-EAQ, LANL is ISO 14001 certified for an EMS, which provides aframework for environmental compliance, pollution prevention, and continual improvement inenvironmental performance. The Laboratory also operates under a ROD issued under the 1999SWEIS.