Table 6
SURA-CEBAF
Fugitive Emissions

Volatile Organic Compounds (VOC)

The majority of fugitive VOCs originate from the use of aerosol sprays such as spray paint,
flux removers, coatings, and welding sprays. Spray paints were by far the largest contributor to fugitive VOCs.

Spray Paint
(600 cans paint/yr) x (15 oz/can) x (1 1b/16 oz) x (90% volatiles) = 506 Ibs/yr

Calculations were performed on all materials used to assess the fugitive emissions.
The remaining sources were nominal yet were added to the spray paint emissions for comprehensiveness.

Total VOC Emissions: 600 Ibs/yr* 0.30 tons/yr*

Hazardous Air Pollutants (HAP)

Chemical CAS # Annual Release*
Methylene Chloride 75-09-2 150.00
Xylene 106-42-3 150.00
Toluene 108-88-3 120.00
1,1,1-Trichloroethane 71-55-6 40.00
Ethyl Benzene 100-41-4 20.00
Methyl Ethyl Ketone 78-93-3 15.00
Hexane 110-54-3 0.50
1A Dioxane 123-91-1 0.30
Hydroquinone 123-31-9 0.04
Totals 495.00 Ib/yr* 0.25 tons/yr*

*Numbers Rounded Up to Provide a Conservative Estimate

SURA-CEBAF D6302.00.01 6/8/95


24

3.0

for the cleansing of niobium cavities, for practical purposes, the usage of
methanol should be discontinued.

Fugitive VOC Emissions Discussion

Fugitive emissions are those emissions not associated with a clearly
identifiable means of conveyance (stack, vent, etc.). Fugitive emissions
typically are released to the atmosphere through windows, doors, and
exhaust fans and are difficult to measure. ERM was able to calculate the
CEBAF’s fugitive VOC and HAP emissions from information collected
from CEBAF and directly from product vendors. The primary source of
fugitive VOC and HAP emissions at CEBAF are spray cans; spray paints,
flux remover, coatings, and welding sprays. As illustrated in Table 6,
CEBAF’s fugitive emissions are insignificant.

PRELIMINARY REGULATORY ANALYSIS

In the Hampton Roads area, a facility is considered a major source of air
pollutants if the facility emits greater than 100 tons of any criteria
pollutant or 250 tons of any combination of criteria pollutants. A source is
also considered major if it emits 10 tons of any of the 189 designated
federal hazardous air pollutants (HAP) or 25 tons of any combination of
HAPs. Ifa source is defined as major, they are then subject to Title V
Operating Permit requirements. Based on the air emissions inventory,
CEBAF is considered a minor source and will not presently be subject to
Title V requirements.

According to Title III of the 1990 Clean Air Act Amendments (CAAA),
major and specific classified sources of hazardous air pollutants will be
subject to maximum achievable control technology (MACT) for their HAPs
emissions. MACT is defined as the average of the top 12% currently
functioning control technology or the top 94 percentile. Thus, the MACT
standard is significantly onerous for facilities with threshold HAP
emissions. Based on the scope of this project, the radionuclide emissions
were not included in this air emissions inventory. Radionuclides are a
federally listed HAP and are regulated according to standards defined in
40 CFR Part 61 Subparts H and Q. ERM recommends that CEBAF assess
its radionuclide emissions to determine its regulatory applicability to the
above standards.

CEBAF incorporates several CFCs which are regulated under CAAA Title
VI. According to Title VI, these CFCs are scheduled to be phased out by
1996. Title VI will not preclude CEBAF from consuming its current

ERM, INC 4 SURA-CEBAR-D6302,00.01-6/8/95


Table 2

SURA-CEBAF Boilers

Actual Emissions-Uncontrolled

RefNo. | Boiler Type | Boiler Capacity | Annual Fuel Use TSPIPM-10 co NOx Sulfur Dioxide VOC
(uMBew/He (MM CUFD war | TONNE Lye | _TONNR” urn | _TONNR uve | TONNR uve | _TONWR

HB1 Cleaver Brooks [ 1.0000 i 1.9000 [142500 [00071 T3900 [00200 [150.000 [00950 | 11400 |  aooos | saa | oor ]
P-142-30

HB2 Cleaver Brooks [ 1.0000 I 1.9000 [142500 "TT o.0071 [395000 [00200 [190.0000 [| 00950 [iso | 000s |  S2s6 | o0me]
142-30

HB3 Cleaver Brooks 3.0000 [ 8.6000, [~~ saso00 [aoa [10.6000 [ova [ 00.0000 [ oasoo | 51000 | o0ms | 2spma | ono J
CB-760-60

HB-4 Cleaver Brooks [ 3.0000 l 8.6000 [_6ss000 | “o1sza [aa0.6000 [oos0a | sso.o000[ oasoo_ | siso0 | 00m | some | ooo]
CB-760-60

HBS Bryan [0.4500 I 0.7000 [~s2500_[o0ozs [14700 [ower [700000 | o0ss0 | oam00 | ooom | 19488 | _o0o10 ]
F.A50WG

HBG Bryan 0.9000 I 1.4000 [ioso00 “[“o00ss 25.4000 [ooua7 | idoo000__[ oor | osso0 | ooo | aoe 100019 |
CL-90wG

HB Bryan [ 0.9000 I 1.4000 [10.5000 [0.0053 [29.400 oora7 140.0000 [ aoroo | oso | 0000s | sae | o0is
cL-90wG

TOTAL ACTUAL EMISSIONS (245000 [183.7500 [0.0919 [514.5000 [0.2573 [2450.00 [12350 [147000 [ 0.0074 [| 682080 | 00381 |

“Emissions determined by AP-42 Emission Factors

SURA-CEBAF D4302.0001 6/8/95


permitting activities in the future. ERM believes that this will not occur
until after the year 2000. Also to ensure that CEBAF will not be subject to
any restrictions in the near future, radionuclide emissions should be
assessed to determine Title II] regulatory applicability. The creation of the
air emissions inventory will allow CEBAF to justify its minor source status
to the Virginia Department of Environmental Quality and/or the U.S.
Environmental Protection Agency and relieve CEBAF of unnecessary
regulatory requirements.

ERM, INC. 6 SURA-CEBAF-D6302.00.01-6/8/95


4.0

5.0

surplus of CFCs however, since the production of these materials will
have ceased, the supply available to the market will be drastically
reduced. CEBAF will need to arrange with vendors substitute materials
for current CFC use.

Finally, the Hampton Roads area is currently a marginal non-attainment
area for ozone. The USEPA is considering adjusting the area’s non-
attainment status to moderate, more serious than marginal. The
adjustment from marginal to moderate will occur, the question is when.
When the adjustment occurs, both new and existing facilities will be
subject to more stringent requirements for VOC and NOx emissions.
CEBAF’s current VOC and NOx emissions are insignificant and should
not be affected by the non-attainment status adjustment.

RECOMMENDATIONS

As a result of this emissions inventory, ERM, Inc. recommends the
following actions for CEBAF.

¢ Radionuclides are a federally listed HAP and are regulated according
to standards defined in 40 CFR Part 61 Subparts H and Q. ERM
recommends that CEBAF assess its radionuclide emissions to
determine its regulatory applicability to the above standards.

¢ CEBAF applied for an air permit in 1988. The Virginia Department of
Environmental Quality-Air Division stated that an air permit was not
necessary at that time. Upon completion of the air emissions
inventory, ERM concurs that an air permit is not necessary for CEBAF
at this time. However, ERM does recommend that CEBAF maintain a
copy of this air emissions inventory report on site for future use in
negotiations with the VADEQ-Air Division.

¢ According to facility personnel, the use of methanol as a cavity
cleansing solution has been discontinued. Methanol is considered a
Federal air toxic as described in § 112 of the Clean Air Act. Removal
of methanol from the cavity cleansing process should reduce future
regulatory requirements.

SUMMARY

The air emissions inventory performed by ERM indicates that CEBAF is a
minor source of air pollution (See Table 7). Therefore, CEBAF should not
be subject to the air operating permit provisions of Title V of the Clean Air
Act. However, it is possible that minor sources will be included in Title V

ERM, INC, 5 SURA-CEBAF-16302.00.01-6/8/95


Table 1

SURA-CEBAF Boilers
Potential Emissions-Uncontrolled

RefNo. | Boiler Type | Boiler Capacity TSPPM0 co z NOx Sulfur Dioxide voc
(MMBtw/Hr) LB/HR__ | _TONNYR LeHR | TONAR LB/HR | __TONYR LeHR | TONYR LBHR | __TONIYR
HB-1 Cleaver Brooks [ 1.0000 Lomo | 0.0300 gaz [0.0900 | ooo | —oaton «| ~—=—s.0006~~=«Y~SC«Ctoaao SYS ~=S«dY~SCS*Ct «ds
P-142-30
HB2 Cleaver Brooks [1.0000 [oo100 | _ 0.0300 oo20 [0.0900 [| _oiooo | —aaton—«|_~—=—so.co0s ===] ~=SCSCmmSSC«dYSC*«‘iétC*d”
P-142-30
HB-3 Cleaver Brooks [ 3.0000 [o0200 [0.0900 0500 | 02600] = 02900 —=«Y| 12500 | ooo «| ~—.n0an | =S.oogo]S0800——=«d:
‘CB-760-60
HB-i Cleaver Brooks [3.0000 [| ___0.0200_—|_——_0.0900 o.oso [02600 [0.2900 12500 | 0.0020 «| —_—0.0080 ooo | _ 00300
‘CB-760-60
HBS Bryan [ 0.4500 [0030 [0.0100 ooo | ooso [ooo dT —ot00 —«|—=—iooos~Ss] Soon] ~—S«dTSCSitom—=«di
E-450WG
HBG Bryan | 0.9000 [0.0060 [0.0300 oor0 | o0s00 | onsoo | ——ossoo «| ~—.00as-—=«t=SC*«=itoSS«d]~SCttSSC«d;~SC*«étS*d
cL-90wG
HB-7 Bryan [ 0.9000 Leor0 [0.0300 oo20 | 0800 [oso «| ~—=—iozaoo ~—=S«dT=SCiomno Ss] ~SSComeS]~SSCes STS «ds;
CL-90WG
TOTAL POTENTIAL EMISSIONS [0.0810 | 0.3100 0.2090 [9.9000 [1.0000 4.3300 [0.0070 ~dT—=—«io2s7—s«T~SCi0a—SC«:~SC«C HO _—=CdY|

“Emissions determined by AP-42 emission factors

SURA-CEBAP D6302.00.01 6/8/95


Southeastern Universities Research
Association-Continuous Electron
Beam Accelerator Facility

Air Emissions Inventory

8 June 1995

Environmental Resources Management, Inc.
812 Moorefield Park Drive, Suite 300
Richmond, Virginia 23236



Table 4

Cavity Cleansing

Potential VOC Emissions

Isopropyl Alcohol/Methanol
Specific Gravity: 0.7915

0.7915 x 8.34lb/gal x 1 gal/3.785 liters= 1.74 Ib /liter
(1.74 Ib/liter)x (0.5 liter) x 1 cavity/2 hr =

(8760 hr/yr) x (0.44 Ibs/yr) x (1 ton/2000 Ib) =

Hazardous Air Pollutants (HAP)-Methanol
0.7915 x 8.34lb/gal x 1 gal/3.785 liters= 1.74 Ib/liter
(1.74 Ib/liter)x (0.5 liter) x 1 cavity/2 hr =

(8760 hr/yr) x (0.44 Ibs/yr) x (1 ton/2000 Ib) =

Table 4a: Assumptions for Cavity Cleansing

incorporated for conservativeness.

Methanol is listed as a federal hazardous air pollutant (HAP).

0.44 Ibs/hr

1.93 ton/yr

0.44 Ibs/hr

1.93 ton/yr

The cleansing solution with the largest specific gravity (Methanol: 0.7915) was

Records from CEBAF Procurement state Methanol use ~ 300 gallons/year.

The Cavity Cleansing process lasts approximately 1 hour per cavity with 1 hour between treatments.

An estimated 0.5 liters is spilled from each cavity; It is assumed that 100% of the spilled material is volatilized.

SURA-CEBAF 16302.00.01 6/8/95


Table 3

NOx Emissions from Niobium Acid Bath

Potential Emissions-Production and Maintenance

(6.2 Moles NOx/cavity) x (46 grams/Mole) x (1 kg/1000 g) x (2.205 Ibs /kg) = 0.527 Ib/cavity
(0.527 Ib /cavity) x (1 cavity /2 hr) = 0.264 Ib/hr
(8760 hr/yr) x (0.264 Ib /hr NOx) x (1 ton/2000 Ib)= * 1.156 ton/yr

Actual Emissions-Production and Maintenance

(600 gal/yr solution) + (30 gal/2 cavities) = 33.3 cavity/yr
Hourly NOx Emission Rate 0.264 lb/hr
(33.3 cavities /yr) x (1 hr /cavity) x (0.264 Ib /hr NOx) x (1 ton/2000 Ib)= 0.004 ton/yr

Table 3a: Assumptions for Acid Bath-NOx Emissions

An average of 5.2 Moles of NOx/cavity is emitted during the niobium acid bath treatment.
Acid Bath process will last approximately one hour per cavity.

Approximately one hour must pass between acid bath treatments.

Use of approximately 500 gallons of acid solution per year for the years 1993-95.

Acid Bath batch process incorporates 30 gallons/batch; One batch equals two cavities.

SURA-CEBAF D6302.00.01 6/8/95


TABLES
SURA-CEBAF
Air Emissions Inventory


2.3

assumed that 100% of the acid solutions disposed of were incorporated in
the cavity acid bath treatment.

According to Table 3, the NO2 potential emissions from the niobium

cavity acid bath are 1.15 tons per year. Considering the emissions level is
based on the maximum potential production of 4380 cavities (1 cavity per
2 hours), the potential NO emissions from acid bathing are insignificant.

Cavity Cleansing

After the cavities exit the acid bath they enter the cavity cleansing process.
The cavities are cleansed to remove any remaining product and surface
impurities. They are filled with four gallons of cleaning solutions
(isopropyl alcohol and methanol) and attached to a vacuum. The cavities
are then rinsed with distilled water and placed in storage. Since volatile
solutions are used in the cleansing process, the primary pollutant of
concern is VOC.

Assumptions made for the niobium cavity cleansing process are indicated
on Table 4a. It is assumed that approximately 0.5 liters or 5% of the
cleaning solution is lost through volatilization. Finally, since methanol is
the most volatile cleansing solution it is used as the model solution in the
emissions calculations.

Based on CEBAF’s Hazardous Waste Disposal Summary Report for 1993-
1995, the amount of cleaning solution disposed is approximately 725
gallons. Assuming that 5% of the solution volatilizes during cleaning, this
725 gallons is 95% of the total cleansing solution usage. These additional
assumptions are indicated on Table 5a.

As indicated in Tables 4 and 5, the VOC emissions are small for a facility
of CEBAF’s size. With a cleansing solution usage rate at over 725 gallons
per year, the potential VOC emissions are approximately 0.44 Ibs per hour
or 1.93 tons per year which makes the cleansing process an insignificant
source.

Methanol is a USEPA designated hazardous air pollutant (HAP).
Methanol usage was treated separately in the cavity cleansing calculations
to determine HAP regulatory applicability. For potential emissions,
methanol was assumed to be the sole cleansing solution. For actual
emissions, ERM calculated that CEBAF used approximately 300 gallons of
methanol per year for the years 1993-95. The total emissions from these
calculations were insignificant. However, since adequate substitutes exist

ERM, INC. 3 SURA-CEBAF-D6302.00.01-6/8/95


Table 7
SURA-CEBAF
Emissions Inventory

Process TSP/PM-10 co NOx Sulfur Dioxide voc HAP
Potential Actual Potential Actual Potential Actual Potential Actual Potential Actual Potential Actual
LB/AR | TON/YR| _LB/YR_| TON/YR| LB/HR| TON/YR|_LB/YR | TON/VR| LB/HR| TONR| LEAR | _LBYR | TON/YR| LB/HR| TON/YR| LBR | TON/YR| LB/AR| TONYR| LB/YR | TON/YR] LBAR|TONYR| LBYR | TON/IYR

Natural Gas 0.08 0.31 183.75 0.09 0.21 0.90 514.50 0.26 1.00 4.33 2450.00 1.23 0.007 0.030 14.700 0.007 0.03 O11 68.21 0.03
Boilers

Cavity Acid 0.26 1.16 0.26 0.004
Bath Treatment

Cavity Solution
Cleansing

0.44 1.93 239.00 0.12 0.44 193 99.00 0.05

Fugitive
Emissions

0.07 0.30 600.00 0.30 0.06 0.25 495.00 0.25

TOTAL
EMISSIONS| 0.08 _ 0.31 | 183.75 0.09 | 0.21 0.90 | 514.50 0.26 | 1.26 5.49 | 0.26 2450.00 1.23 | 0.007 0.030 /14.700 0.007] 0.54 2.34 | 907.21 0.45 | 0.50 2.18 | 594.00 0.30

SURA-CEBAF 16302,00.01 6/8/95


21

2.2

Natural Gas Boilers

CEBAF has seven natural gas boilers located throughout the facility for the
primary purpose of space heat. The boilers are all relatively small and are
considered exempt from state air permitting requirements. The “AP-42”
Emission Factors defined by the United States Environmental Protection
Agency (USEPA) were used to establish criteria pollutant emission levels
for the boilers. Both potential and actual boiler emissions were calculated
and included in Tables 1 and 2 respectively. As indicated in Tables 1 and 2,
the total criteria pollutant emissions from the boilers are small.

Niobium Cavity Acid Bath

CEBAF constructs cavities from niobium, a superconducting ductile metal,
for use in the electron beam accelerator. During construction, the cavities
are surface-cleaned and finished in an acid bath. An equal mixture of
nitric, phosphoric, and hydrofluoric acids are used to remove
approximately 2-4 mils of surface area to provide a smooth, polished
surface. An exhaust system is located over the acid bath area which
removes acid gases and NO? to a scrubber system. The collection
efficiency of the scrubber on the acid gases is approximately 85% while the
collection efficiency of NO2 is nominal. For the purpose of this air
emissions inventory, ERM assumed that NO? emissions are uncontrolled.
NO is the only criteria pollutant of concern in the acid bath process.

The Basic Acid Bath Reaction: 2 Nb +5NO3 --> Nb2Os5 + 5NO2

Several calculations have been based on data supplied by CEBAF.
Assumptions have been made to accept the validity of this data and to
address any data gaps that may exist. Assumptions made for the Niobium
Cavity Acid Bath process are indicated on Table 3a. According to the
CEBAF air permit application dated 13 December 1988, the acid bath
utilizes 30 gallons for two cavities and lasts one hour per cavity. The
calculations in the application indicate that NOz emissions from the acid
bath are 0.527 pounds per hour. According to CEBAF personnel, the acid
bath treatment requires an additional hour between treatments to allow for
acid temperature equalization resulting from a rather high exothermic
reaction. Therefore, ERM assumed a rate of 0.527 pounds per two hours or
0.267 pounds per hour.

As indicated in CEBAF’s Hazardous Waste Disposal Summary for the years
April 1, 1993-March 31, 1995, ERM was able to estimate that approximately
500 gallons per year of acid solution were disposed as waste. It was

ERM, INC. 2 ‘SURA-CEBAF-D6302.00.01-6/8/95


1.0

2.0

INTRODUCTION

On 8 May 1995, Environmental Resources Management, Incorporated
(ERM) conducted a site visit of the Southeastern Universities Research
Association-Continuous Electron Beam Accelerator Facility (CEBAF) in an
effort to produce an air emissions inventory outlining the facility’s actual
and potential air emissions. An inspection of the facility was performed,
interviews were held with relevant facility personnel, and appropriate
documents and data were collected.

The air emissions inventory was performed at the request of CEBAF to
assess the facility’s future regulatory requirements. The primary areas of
investigation were the seven (7) natural gas boilers, cavity acid treatment,
cavity cleansing, and fugitive emissions. Radionuclides were not included
in the scope of this emissions inventory.

DATA EVALUATION

The process emissions for CEBAF have been outlined and described in
detail in the following text and corresponding tables. All emissions are in
terms of a weighted time average such as pounds per hour or tons per
year. These terms were chosen to correspond with established emission
factors and compliance parameters.

Information for the emissions inventory was collected from various
sources including: permits and applications, registration updates,
purchasing records, product inventories, waste summaries, and personnel
interviews. The information was incorporated into the emissions
summaries with data gaps addressed through conservative assumptions.
All assumptions made in the emissions inventories are defined in detail.

Both potential and actual emissions are defined for all process areas.
Potential emissions are defined as the maximum possible emissions
discharged from a piece of equipment operating at 100% capacity for

24 hours per day, 7 days per week, and 52 weeks per year for a total of
8760 hours per year. Potential emissions are the basis for most regulatory
requirements. Actual emissions are, as stated, the equipment’s actual
emissions. Normally, two or more years of actual emissions are used to
assess the equipment’s typical emissions as compared to its operating
parameters to determine a normal operating emissions schedule for the
piece of equipment.

ERM, INC. 1 ‘SURA-CEBAF-D6302.00.01-6/8/95


Table 5

Cavity Cleansing
Actual VOC Emissions
Cleansing Solution Usage
0.7915 x (8.34 Ib/gal) x (725 gal/yr*)= 4785 Ib/yr Designated Waste Cleansing Solutions
VOC Emissions
(4785 Ib/yr) x 5% volatilized*= 239 lb/yr* VOC Emissions
* See Assumptions below for an explanation.
Hazardous Air Pollutants (HAP)-Methanol
(300 Gallons of Methanol) x (8.34 Ib/gallon) x (0.7915) = 1980.00 Ibs/yr
(1980.00 Ibs/yr) x 5% volatilized = 99 lb/yr Methanol Emissions

Table 5a: Assumptions for Cavity Cleansing-VOC Emissions

The cleansing solution with the largest specific gravity (Methanol: 0.7915) was
incorporated as a form of conservatism.

Disposal of approximately 725 gallons of cleansing solution per year for the years 1993-95.
(CEBAF Haz. Waste Disposal Summary)

* Anestimated 0.5 liters of cleansing solution is lost through volatilization.
(It is estimated that the volatilized product is equal to = 5% of the total cavity volume).

It is assumed that 100% of all solutions spilled are evaporated.

.

Records from CEBAF Procurement state Methanol use = 300 gallons/year.

SURA-CEBAF D6302.00.01 6/8/95