Chapter 30 Table of Contents. View the entire chapter in a PDF format. Please use the pdf for printing.

Requirements:
General (5.1)

The primary objective of the air quality program is to achieve and maintain compliance with both SLAC-specific permit conditions and other, more generic, regulatory requirements. This involves preparing and submitting permit applications and renewals, coordinating emissions tracking and recordkeeping, preparing regulatory deliverables, and reviewing proposed operations that have the potential to generate air emissions. The recordkeeping process incorporates periodic reviews to evaluate monitoring data for potential emissions reductions.

While the air quality program manager takes the lead in these activities, other SLAC personnel play important roles. Two most important are described here.

Emissions Source Custodian

The emissions source custodian is the recordkeeping contact for a given emissions source. This role is designated by line management, the work area supervisor, or the area manager. Typically, the emissions source custodian is the person most closely involved with the daily operations associated with the source.

Site Owner

The site owner is typically the supervisor who oversees the emissions source custodian. A site owner evaluates all recommendations for emissions reduction and corrective actions.

Emissions Source Permitting and Permit Renewal

Clean Air Act Programs and the SLAC Permit

SLAC is subject to Title V of the Clean Air Act, which offers three regulatory pathways (for large, medium, and small generators of air pollutants) to achieve compliance. SLAC falls into the category of a medium-sized facility, and so a synthetic minor operating permit (SMOP) was the most appropriate avenue. Essentially, this permit indicates that SLAC is not classified as a major source of air pollutants but has the potential to exceed the defining threshold of 25 tons/year of hazardous air pollutants. The SMOP is renewed annually and incorporates all the separate permits issued for individual emissions sources. Primary requirements of the SMOP include monthly recordkeeping and reporting, along with proper maintenance and periodic inspections.

SMOP/PTO Permit Renewal

The SMOP/PTO, or umbrella permit, is subject to renewal each July. The permit renewal fee is due July 1, and it is prorated from emissions data from the previous 12-month period. The annual emissions summary is due July 31.

Note: New permits are no longer posted on approved emissions sources, since emissions source limits are managed on a site-wide basis. The program manager keeps all approved permits on file, and they are available for inspection in keeping with BAAQMD rules and regulations.

Gasoline Dispensing Facility Permit Renewal

The gasoline dispensing facility (GDF) is the only permitted emissions source at SLAC for which a separate permit is maintained, even though GDF emissions are included in the emissions reports required under the umbrella permit. The GDF permit is renewed annually after a source test is successfully performed. The source test is coordinated with the SLAC Fleet Services Group within the Conventional and Experimental Facilities Department (CEF) by the program manager and is conducted by a licensed subcontractor.

Note: Despite its name, the GDF also dispenses Biodiesel 20 to diesel powered vehicles and equipment. This fuel reduces air emissions without compromising efficiency or requiring engine modifications.

New Emissions Source Permits

Every new emissions source must be evaluated by the air quality project manager to determine whether it requires an air permit. A new source can be a newly purchased piece of equipment or a modified existing source, depending on the nature of the modification. If a permit is required, the program manager prepares and submits an application; upon its approval, a new permit is issued for that source for a period of one year. However, at the next general permit renewal the new emissions source and concomitant permit conditions are incorporated into the facility-wide SMOP. This consolidation greatly simplifies the renewal process.

Note: The permitting process may require weeks or months, depending on the proposed emissions source. To prevent delays, initiate the permitting process as early as possible by contacting the program manager in the planning stages of the project to identify and evaluate sources of air emissions.

Accelerated Permitting Process

Proposed projects that meet specific criteria (for example, minimum distance from the nearest school, low emissions volume) may qualify for accelerated permitting under the BAAQMD regulations. Once a complete application package is submitted by the program manager, the operation may proceed without waiting for completion of the formal review.

Permit Conditions

Accurate tracking and recordkeeping of permitted emissions sources is critical to achieving and maintaining regulatory compliance with permit conditions.

Emissions Tracking

Two methods are used to track permitted emissions: purchasing records and use logs. Although actual use data is preferable, purchasing records provide an acceptable leading indicator of chemical usage.

Purchasing Records

All hazardous materials must be purchased through the chemical management services (CMS) system in order to facilitate "cradle-to-grave" chemical tracking. Purchases of individual chemicals are summarized annually, and the total quantities are reported in regulatory deliverables.

Note: All new chemicals proposed for addition into the CMS database must be evaluated by ES&H program managers and subject matter experts for potential hazards, air emissions, special storage requirements, usage restrictions, and possible substitutes.

Use Logs for Construction Projects

Monthly recordkeeping has long been the standard mechanism for monitoring permitted sources of air emissions (see Section Error! Reference source not found., "Error! Reference source not found."), and now applies to longer-term construction projects as well. Use logs must be provided to the program manager on a monthly basis to monitor use of the following categories of equipment and materials:

• SLAC-owned equipment. All such equipment (whether used for construction or routine operations) having actual or potential air emissions must be evaluated by the program manager and permitted if necessary. Once a source is permitted, monthly hazardous material use, fuel consumption, and/or equipment operation logs must be kept, as appropriate. In addition, it must be inspected at least semi-annually to ensure proper operation and compliance.
• Subcontractor-owned equipment. All such equipment must be registered with the CARB under the statewide portable equipment registration program (PERP). This program allows registered portable equipment to be operated anywhere in the state without having to obtain a permit for each individual location or project. Monthly hazardous material use, fuel consumption, and equipment operation logs must be kept. This requirement applies primarily to generators, boilers, or other portable equipment brought on-site temporarily for a specific project.
• Project-specific hazardous materials. A pre-work hazardous material list must be submitted to the program manager prior to the start of work. This list provides the basis for a HazMat use report at the end of the month or at the end of the project, whichever comes first. For longer-term projects, monthly use logs must be filled out and submitted to the program manager.

Note: All project-specific hazardous materials must be tracked, including those brought on-site by subcontractors. As such, project managers may want to consider purchasing all project-related materials through the CMS and providing them to the subcontractor in order to simplify HazMat tracking requirements.

Recordkeeping

The program manager compiles and analyzes monthly emissions data supplied by emissions source custodians and keeps a cumulative tally for each source. (For detail, see Air Quality: Roles, Responsibilities, and Authorities Matrix [pdf].) This allows the program manager to provide timely feedback to any emissions source custodian if a particular source may be approaching a regulatory threshold value. In addition, quarterly summaries are routinely provided to emissions source custodians for their review.

Permit-exempt Emissions Sources

In order to maintain permit-exempt status, these sources must be properly maintained and periodically inspected. Inspections and maintenance should be documented to show compliance with applicable requirements.

Inspections

Periodic inspection of both permitted and permit-exempt emissions sources, including abatement devices, is required semi-annually, at a minimum, in order to verify or update the regulatory status of each source.

Reporting

Regulatory Deliverables

The program manager is responsible for preparing a wide range of annual reporting deliverables to federal, state, and regional governmental agencies, as listed in Air Quality: Reporting Requirements [pdf].

Reportable Equipment Malfunction

Under the new BAAQMD Reportable Compliance Activities Program, all regulated facilities are required to report in a timely manner any operating irregularity or monitoring anomaly that may indicate or result in excess emissions. Emissions source custodians must notify the program manager immediately to determine specific reporting requirements.

Emissions Control or Reduction

As formalized in the integrated safety and environmental management system (ISEMS) program, SLAC endeavors to minimize environmental impacts by analyzing risks, collecting monitoring data, reviewing industrial processes, investigating the use where feasible of abatement strategies and technologies, and encouraging continual process improvement. Separate permits are issued by BAAQMD for abatement devices to control emissions sources that otherwise would not be allowed to operate.

Risk Management Plan

Under the California Accidental Release Prevention Program (CalARP), SLAC is required to maintain a risk management plan (RMP) for any subject chemical that is stored or used on-site above its respective threshold. Currently, the only chemical regulated under CalARP is potassium cyanide, which is used in the Plating Shop Complex and stored as hazardous waste in the Hazardous Waste Storage Area (HWSA).

Hazardous Materials

As required by JHAMs, all persons working with hazardous materials should periodically review the material safety data sheet (MSDS) for all chemicals used in their respective work areas to identify any changes that may affect personal protective equipment (PPE), contingency procedures, or other aspects of hazard mitigation. In particular, the actual or potential air emissions associated with each chemical needs to be understood, since they are typically less obvious than visible hazards. One possible forum for this review is the annual performance evaluation for each employee during which the JHAM is reviewed and updated as necessary.

Note: When ordering chemicals, check each MSDS for updates, especially for routinely used chemicals. If workable alternatives to hazardous materials are available, choose the least hazardous material.

Process Improvements

Under the ISEMS, any ideas for process improvements that would reduce emissions or increase efficiency are strongly encouraged and should be brought to the attention of the program manager.

Vehicle Emissions

SLAC's no-idling vehicle policy applies to all on-site vehicles and comprises two distinct elements:

1. After starting the engine, minimize idling time and set the vehicle in motion immediately; be prepared to drive before turning the ignition key.
2. Turn the engine off whenever the vehicle is to be left unattended for any length of time.

Implementation of this policy is ongoing and will involve articles on the SLAC website, dashboard stickers, mailbox flyers, or other reminders, as appropriate.

Hazardous Waste Disposal

In addition to air emissions, certain emissions sources produce hazardous waste that must be managed by the Waste Management Group (WM). Requirements for hazardous waste disposal include obtaining appropriate containers from WM, regularly inspecting waste accumulation areas, and following all requirements of Chapter 17, "Hazardous Waste".

Note: Examples of hazardous wastes associated with emissions sources include spent solvents, wipes contaminated with solvents and oils, debris and waste from construction projects, baghouse waste from (as an example) the Metal Finishing Pre-Treatment Facility (MFPF), and waste from the paint shop.

Personnel

Personal Protective Equipment

Anyone working with or around an emissions source must comply with all safety notices, such as warnings posted in area signage, or precautions specified in the MSDS for the associated hazardous material(s).

continue to Requirements, Roles & Responsibilities (5.1.7)