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2.3 Proposed Limits For Title III Applicability

LANL is requesting emission limits to remain a minor source of HAP emissions under the Clean Air Act Title III requirements. They are proposing a limit of 8 tons per year for any individual HAP and 24 tons per year total HAPs. This would keep their emissions below the major source threshold of 10 tons per year for a single HAP or 25 tons total. They would demonstrate compliance by calculating actual emissions from all non-insignificant sources twice a year.

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39 views

2.3 Proposed Limits For Title III Applicability

LANL is requesting emission limits to remain a minor source of HAP emissions under the Clean Air Act Title III requirements. They are proposing a limit of 8 tons per year for any individual HAP and 24 tons per year total HAPs. This would keep their emissions below the major source threshold of 10 tons per year for a single HAP or 25 tons total. They would demonstrate compliance by calculating actual emissions from all non-insignificant sources twice a year.

Uploaded by

Adamu Enemona Kogh
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© © All Rights Reserved
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2.

3 Proposed Limits for Title III Applicability

Similar to the PSD discussion above, LANL is requesting facility-wide emission


limits on HAPs to keep the facility a minor source of HAP emissions, and therefore not
subject to the 1990 CAAA Title III requirements. The 1990 CAAA provided a list of 189
hazardous air pollutants. Since the original list was published, caprolactum has been
delisted. Therefore, the current list includes 188 compounds included as regulated HAPs.
The Title III major source threshold is 10 tons per year of any one HAP or 25 tons per
year of all HAPs combined.

Emissions from fugitive and area sources must be included in the facility-wide
totals when evaluating whether the facility is a major source under Title III. Therefore
HAP emission estimates from open burning/open detonation (OB/OD) and remediation
activities are included in this section.

As shown in Table 2.1-2, the Laboratory’s actual HAP emissions are well below
the Title III major source threshold. See Table 3.6-2 for speciated HAP data for chemical
use. The largest source of HAP emissions at LANL is from chemical use in support of
various research and development activities. The second largest source of HAP
emissions is from fuel combustion in boilers and heaters. LANL is proposing emission
limits of 8 tons per year for any one HAP and 24 tons per year of total HAPs. Chapter 3
of this application provides details about individual emission units and source categories
and specific operational limits LANL proposes to ensure HAP emissions stay below the
requested facility-wide limits. Table 2.3-1 shows the proposed HAP allowable emission
limits. Each emission limit proposed is on a 12-month rolling average basis.

Compliance with the proposed facility-wide emissions limit will be demonstrated


by calculating actual emissions from all sources that are not insignificant on a semiannual
basis.

Table 2.3-1. Proposed Emission Limits for Facility-Wide HAPs


Pollutant Proposed Allowable Limit
(ton/year)
Total Facility-wide HAPs 24
Individual Facility-wide HAPs 8

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