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A w LosAlamos
NATIONAL LABORATORY --- EST1943 --shy
Environmental Stewardship Division Meteorology and Air Quality Group PO Box 1663 MS J978 Date December 20 200~ Los Alamos New Mexico 87545 Referto ENV-MAQ04-419 (505) 665-8855FAX (505) 665-8858
Mr Ted Schooley Program Manager New Source Review Air Quality Bureau New Mexico Environment Department 2048 Galisteo Street Santa Fe NM 87505
IDEA ID 856 Los Alamos National Laboratory Notice of Intent for the T A-54 MDA L Soil Vapor Extraction Project
Dear Mr Schooley
Enclosed are four copies of a Notice of Intent application for a proposed new soil vapor extraction pilot test at Los Alamos National Laboratorys (LANL) Material Disposal Area (MDA) L located at Technical Area (TA) 54 LANL is submitting this Notice of Intent application under 20273 NMAC in order for NMED to review the proposed project and LANLs determination that a construction permit is not required Also attached is the required $500 filing fee for this application
MDA L is a closed disposal site which was previously used from the early 1960s until 1985 for treatment and disposal of non-radiological liquid chemical wastes including chlorinated solvents Portions of the site are regulated by the NMED under the Hazardous Waste Act (HWA) corrective action authority As such a subsurface hydrocarbon vapor plume has been characterized and alternative technologies require evaluation under the corrective action process
LANL is proposing at this time a pilot study using a soil vapor extraction (SVE) system to provide information on the volume and rate ofplume reduction It is uncertain at this time how long the SVE system may operate following evaluation of results However this application assumes conservatively the system will operafe 24 hours per day and 365 days per year
SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist ofextraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbons present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit
Air emissions from the SVE system can be characterized as either volatile organic compounds (VOCs) or non-particulate hazardous air pollutants (HAPs) Besides VOCs there are no other criteria pollutants emitted from the process Maximum potential VOC emissions are estimated to be 761bhr and 17 tpy These estimates do not include the destruction efficiency ofthe catalytic
The Worlds Greatest Science Protecting Americ An Equal Opportunity Employer I Operated by the University of California for DC 30512
11111111111111111111111111111111111
i Ifrshy 4
Mr Ted Schooley -2- December 20 2004 ENV-MAQ04-419
oxidation unit Maximum actual VOC emissions considering a 95 reduction from catalytic oxidation are estimated to be 04 Iblhr and 01 tpy
20272 NMAC does not currently require a construction permit for a new or modified minor source which emits only VOCs As described in Attachment I of this application we do not believe there are any other provisions of 20272 NMAC which require issuance of a permit for this project
We have also determined that the SVE Project will not qualify as an insignificant activity under the Title V program and 20270 NMAC Therefore we will need to revise the LANL operating permit to include the SVE system As described in Attachment I we believe that NMEDs review of this application constitutes preconstruction permit review as intended by Subsection C(3) of Section 404 of20270 NMAC This means assuming you concur a construction permit is not required for this project LANL may begin construction and operation of the SVE system upon receipt ofyour determination and must then file a Title V modification within 12 months from the start of operation of the SVE system In your response to this application please indicate your response to this assessment with respect to Title V requirements
Please contact Bill Blankenship at 665-0823 with any questions you may have regarding the application
Sincerely ~
J ~~ j1i ~t0 ---_J
Jean Dewart Group Leader Meteorology and Air Quality
JMDdb
Enc a1s
Cy Ned Jerabek NMEDAir Quality 2048 Galisteo Street Santa Fe NM 87505 John Kieling NMEDlHazWaste 2905 Rodeo Park Dr East Bldg 1 Santa Fe NM 87505-6303 Alison Dorries ENV -ECR M992 John Hopkins ENV -ECR M992 Kristi Beguin SEA C300 Phil Wardwell LC-ESH A187 Alice Barr ENV -SWRC K490 Steve Fong DOE-LA-AO A316 Woody Woodworth DOE-LASO A316 David Gregory DOE-LASO A316 Dennis McLain NOW-NA J910 Gilbert Montoya NOW-SWO J595 Dianne Wilburn ENV -MAQ J978 Jackie Hurtle ENV-MAQ J978 Steve Story ENV-MAQ J978 Bill Blankenship ENV -MAQ J978 ENV -MAQ File
I
Dec-17-200~ 054E~ From-LANL RRES r~ 5056658190 T-884 ~OOl001 F-843 0
~ ~ LosAlamos
TlO ~ ilOII TOI ---urn gt
SignatureReviewCoordination Sheet This form is to accompany all documents requinl9 review approval Or signature Dy G Peter Nanos Director
Deaoline lDate 121704 122004 I Is 11llS a response to an actIon Item Yes 0 No Iti From o Call for PICk-up
bull Name Kcn Hargis MS Name Pnone
TITLE loentTy coumem Dtlell) Oelicn)s 1080 matter Notice of Intent for the r A-54 MOA L Soil Vtpor Extraction ProjectI Action
o Information only BACKGROUNO
ISSUES
Ken needs [0 have Jackie ana Jean sign off bcforc hell Slsn etf
I ACTION requesliC of DirKtOr
OLD or ALe encorsement
Name (pnnr
CoordinateCS wj~h 1_ Name (pnm)
Jackje Hunk
2 Name (pMl)
Jean Dc art
3 Namamp (pnnl)
I 4 Name (prim) I
Signature
Signature
Signature Date
Please enSurE appropmlte tnte(intra DirectorateDlvJslonal coorOlnatJon anc reView pnor to submmal to tna Direcor_
Form 1824 (804)
Mail Application To Application No ______
New Mexico Environment Department Air Quality Bureau New Source Review Unit 2048 Galisteo AIRS No ____________ Santa Fe NM 87505
Phone (505) 827-1494 For NMED use onlyhttpwwwnmenvstatenmus
Air Quality Permit Application And Notice Of Intent Universal (General) to Construct or Modify
Acknowledgement x I acknowledge that a pre-application meeting is available to me upon request
X Permit filing fee enclosed Check No S 1~ CO lt
Part I - General Information I-A Company Information
I Company name University of California for the US Department of Energy Date application notarized 12ltgt 0 t
2 Facility name Los Alamos National Laboratory SIC code (4 digits) 9711
3 Companymailing address Meteorology and Air Quality Group PO Box 1663 MS J978 Los Alamos NM 87545
4 Contact person Jean Dewart I Title Group Leader
5 Phone No 505-665-0239 IFax No 505-665-8858 IE-mail dewartlanlgov
I-B Current Facility Status
I This application is for (check one) New Facility X Modification to an existing facility or Revision
2 Has this facility already been constructed XYes ONo I Ifyes is it currently operating in New Mexico XYes ONo
3 Is the plant currently shut down DYes XNo I Ifyes give month and year of shut down (MMlYY) NA
4 Was this facility constructed before 1972 and operated since 1972 X Yes ONo
5 Does this facility have an operating permit under 20 NMAC 270 X Yes DNo If yes the permit No is P- 100
6 Has this facility been issued a No Permit Required (NPR) X Yes [No Ifyes the NPR number is 2195A
7 Has this facility been issued a Notice of Intent (NOl) X Yes ONo IUyes the NOI Number is 2597
8 Does this facility have a construction permit (20 NMAC 272 Section 200A or 200B) X Yes [No
bull Ifyes the permit No is 2195 2195-BM1 2195-F 2195-8
1
9 Has this facility been issued a general permit (GCP-I GCP-2 ) X Yes ONo I Ifyes the registration No is GCP3shy
2195G
10 Is this a major source under the PSD rules DYes X No OUnsure I Is this a major source under Title V (20 NMAC
bull 270) X Yes [No [Unsure I Is this a major modification under the PSD rules (20 NMAC 274) DYes X No OUnsure
11 If Yes or Unsure to any of the questions in question No 10 contact the AQB to see if a pre-application meeting is required
Rev 71802
Table ImiddotB Current Facility Status (continued)
12 What is the facilitys maximum input capacity specify units (reference here and list capacities in Attachment L if more room is required)
bull Current Hourly NfA Daily NfA Annually NfA
bull Proposed Hourly 6000 scf Daily 144000 set1 Annually 526 X 10 scf
13 What is the facilitys maximum production rate specify units (reference here and list capacities in Attachment L ifmore room is required)
bull Current Hourly NtA Daily NtA Annually Nt A
bull Proposed Hourly 6000 setl Daily 144000 set1 Annually 526 X 106scfl
Values are based on maximum capacity ohml vapor extraction system to extract 100 sefm of soli pore-gas for treatment
Table laC Facility Location Information
1 Section 36 IRange 6E ITownship 19N ICounty Los Alamos I Elevation (ft) 7400
2 UTM Zone 012 or X13 IUTMH (record to one tenth ofa Ian) 3869 IUTMV (record to one tenth of a Ian) 39664
OR Latitude (deg min sec) I Longitude (deg min sec)
3a Name and zip code of nearest New Mexico town Los Alamos 87544
3b Distance and Direction from nearest New Mexico town Approximately 5 miles southeast of Los Alamos
4 Detailed Driving Instructions from nearest NM town (attach a road map if necessary)
The facility is __5__ (distance) miles ___SE_ (direction) L Alamos (nearest town) with entrance offof Pajarito Road (road accessible to LANL bad2e holders only)
5 Status ofland at facility (check one) DPrivate llndiantPueblo X Government
6 Name ofnearest Class I area to the facility (see Figure 10) Bandelier Wilderness Area
7 Shortest distance from TA-54 boundary to the boundary of the nearest Class I area (record to one tenth ofa Ian) 55km
Table ImiddotD Proposed Operating Schedule (Note the operating schedule (D1 D2) shall become a condition oUhe permit)
I FT (hOursaCI tty maximum operatIng day) 24 I (days ) 7 week
I weeks(--) 52 year I hours(year ) 87fiO
2 Facilitys maximum daily operating schedule (ifless than 24 h~) Start NA IDAM IDPM End NA I DAM CPM
3 Month and year of anticipated start of construction April 2005
4 Month and year of anticipated construction completion April 2005
5 Month and year of anticipated startup of new or modified facility April 2005
6 Will this facility operate at this site for more than one year X Yes CNo (IfSVE system is selected remediation option)
Table 1-1 Other
1 Is this application in response to a Notice ofViolation (NOV) DYes X No
bull Ifyes NOV date NA INOV Tracking No NA
2 Is air quality dispersion modeling being submitted with this application DYes X No
3 Does this facility require an Air Toxics permit under 20 NMAC 272 Part IV Tables A andor B in Part V DYes X No
4 Will this facility be a source offederal Hazardous Air Pollutants X Yes ON0
bull Ifyes list applicable subparts in 40 CFR 61 amp 63 None
Rev 71802 2
Part II - Required Attachments
The following Attachments are required please label each accordingly A complete application shall include
Attachment A A process flow sheet andor block diagram indicating the individual equipment all emission points and types of control applied to those points Numbering system should cross reference with Attachment B
Attachment B A plot plan drawn to scale showing emissions points structures tanks and fences of property owned leased or under direct control of the applicant
Attachment C All calculations used to determine both the hourly and armual controlled and uncontrolled emission rates Reference where emission factors were obtained If identical units are being permitted and will be subject to the same operating conditions submit calculations for only one unit and a note specifying what other units the calculations represent
Attachment D Information Used to Determine Emissions bull If manufacturer data are used include specifications for emissions units and control equipment If test data are used include a copy of the complete test report If the test data are for an emissions unit other
than the one being permitted the emission units must be identical Test data may not be used if any difference in operating conditions ofthe unit being permitted and the unit represented in the test report significantly effect emission rates
bull If the most current copy of AP-42 is used reference the section and date located at the bottom of the page Include a copy of the page containing the emissions factors and clearly mark the factors used in the calculations
bull If an older version of AP-42 is used include a complete copy of the section bull If an EPA document or other material is referenced include a complete copy bull Fuel specifications sheet bull If computer models are used to estimate emissions include an input summary (if available) and a detailed
report and a disk containing the input file(s) used to run the model For tank-flashing emissions include a discussion of the method used to estimate tank-flashing emissions relative thresholds (ie permit or major source (NSpS PSD or Title V)) accuracy of the model the input and output from simulation models and software all calculations documentation of any assumptions used descriptions of sampling methods and conditions copies of any lab sample analysis
Attachment E A map such as a 7S minute topographic quadrangle showing the exact location of the source The map shall also middot ldthtlle 0 owmgmc u e The UTM or Longitudinal coordinate system on both axes An indicator showing which direction is north A minimum radius around the plant ofSkm (31 miles) The nearest occupied structure(s) Topographic features of the area Access and haul roads The name of the map Facility property boundaries A scale The area which will be restricted to public access
Attachment F Proof of public notice Include a copy of the certified letter receipts a list of the places where the public notice has been posted and (see guidance document)
a sample of the letters sent to land owners a sample and verification of the local po stings a sample of the letters sent to municipalities a copy of the display ad and its affidavit ofpublication a copy of the announcement sent to a local radio station a copy of the classified ad and its affidavit of
publication
Attachment G A written description of the routine operations of the facility Include a description of how each piece of equipment will be operated how controls will be used and the fate of both the products and waste generated For modifications andlor revisions explain how the changes will affect the existing process
Attachment H A PSD applicability determination for all sources For PSD major sources applying for a significant permit revision use the procedures for Determining the Net Emissions Change at a Source as specified by Table A-5 (Page A45) of the EPA New Source Review Workshop Manual to determine if the revision is subject to PSD review
Attachment I A discussion demonstrating compliance with each applicable state amp federal regulation If there is a state or federal regulation for your facilitys source category that does not apply to your facility explain why For example 40 CFR 60 Subpart 000 (crushers) 40 CFR 63 Subpart HHH (HAPs) or 20 NMAC 274 (PSD major sources)
Rev 711802 3
Attachment J A preliminary operational plan defining the measures to be taken to mitigate source emissions during malfunction startup or shutdown
Attachment K An air quality dispersion modeling demonstration (if applicable) as outlined in the Air Quality Bureaus Dispersion Modeling Guidelines
Attachment L Other relevant information Use this attachment to clarifY any part in the application that you think needs explaining Reference the section table column andor field
Submit the original signed and notarized copy of the application package and
1) One working copy for department use and 2) One copy if air dispersion modeling is included (include disks with input and output files) and 3) One copy ifpublic notice was required and 4) If subject to PSD review under 20 NMAC 274 (PSD) one copy for US EPA one copy for each federal land
manager affected (NPS USFS FWS USDl) and one copy for each affected regulatory agency other than the Air Quality Bureau
Rev 71802 4
Part III - Production and Control Equipment
Table III-A Regulated Equipment (Unit and stack numbering must correspond throughout the application package) Note If applying for a NOI under 20 NMAC 273 equipment exemptions under 272202 do not appi) and all equipment should be listed here
Manufacshyturer Model No
Date of Capacity Applicable Unit Manufacture Type (Specify For Each Piece of Equipment State Reg (s) ReplacingReconstruction No (MMDDIYY) Serial No (Source Description) Units) Check One 20 NMAC 2X Unit No
Catalytic 2027 NMAC CAT- Combustion
20261 NMAC OX-1
Corporation 100E o Existing (unchanged) o To be Removed X NewAdditional o Replacement Unit 20270 NMAC
2004 TBD Electric catalytic oxidizer 100 sefm o To be Modified [l To be Replaced 20273 NMAC NA
o Existing (unchanged) [l To be Removed n NewAdditional [1 Replacement Unit o To be Modified lJ To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit n To be Modified o To be Replaced
o Existing (unchanged) [J To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
[J Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit
Io To be Modified o To be Replaced
Rev 71802 5
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
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Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Mr Ted Schooley -2- December 20 2004 ENV-MAQ04-419
oxidation unit Maximum actual VOC emissions considering a 95 reduction from catalytic oxidation are estimated to be 04 Iblhr and 01 tpy
20272 NMAC does not currently require a construction permit for a new or modified minor source which emits only VOCs As described in Attachment I of this application we do not believe there are any other provisions of 20272 NMAC which require issuance of a permit for this project
We have also determined that the SVE Project will not qualify as an insignificant activity under the Title V program and 20270 NMAC Therefore we will need to revise the LANL operating permit to include the SVE system As described in Attachment I we believe that NMEDs review of this application constitutes preconstruction permit review as intended by Subsection C(3) of Section 404 of20270 NMAC This means assuming you concur a construction permit is not required for this project LANL may begin construction and operation of the SVE system upon receipt ofyour determination and must then file a Title V modification within 12 months from the start of operation of the SVE system In your response to this application please indicate your response to this assessment with respect to Title V requirements
Please contact Bill Blankenship at 665-0823 with any questions you may have regarding the application
Sincerely ~
J ~~ j1i ~t0 ---_J
Jean Dewart Group Leader Meteorology and Air Quality
JMDdb
Enc a1s
Cy Ned Jerabek NMEDAir Quality 2048 Galisteo Street Santa Fe NM 87505 John Kieling NMEDlHazWaste 2905 Rodeo Park Dr East Bldg 1 Santa Fe NM 87505-6303 Alison Dorries ENV -ECR M992 John Hopkins ENV -ECR M992 Kristi Beguin SEA C300 Phil Wardwell LC-ESH A187 Alice Barr ENV -SWRC K490 Steve Fong DOE-LA-AO A316 Woody Woodworth DOE-LASO A316 David Gregory DOE-LASO A316 Dennis McLain NOW-NA J910 Gilbert Montoya NOW-SWO J595 Dianne Wilburn ENV -MAQ J978 Jackie Hurtle ENV-MAQ J978 Steve Story ENV-MAQ J978 Bill Blankenship ENV -MAQ J978 ENV -MAQ File
I
Dec-17-200~ 054E~ From-LANL RRES r~ 5056658190 T-884 ~OOl001 F-843 0
~ ~ LosAlamos
TlO ~ ilOII TOI ---urn gt
SignatureReviewCoordination Sheet This form is to accompany all documents requinl9 review approval Or signature Dy G Peter Nanos Director
Deaoline lDate 121704 122004 I Is 11llS a response to an actIon Item Yes 0 No Iti From o Call for PICk-up
bull Name Kcn Hargis MS Name Pnone
TITLE loentTy coumem Dtlell) Oelicn)s 1080 matter Notice of Intent for the r A-54 MOA L Soil Vtpor Extraction ProjectI Action
o Information only BACKGROUNO
ISSUES
Ken needs [0 have Jackie ana Jean sign off bcforc hell Slsn etf
I ACTION requesliC of DirKtOr
OLD or ALe encorsement
Name (pnnr
CoordinateCS wj~h 1_ Name (pnm)
Jackje Hunk
2 Name (pMl)
Jean Dc art
3 Namamp (pnnl)
I 4 Name (prim) I
Signature
Signature
Signature Date
Please enSurE appropmlte tnte(intra DirectorateDlvJslonal coorOlnatJon anc reView pnor to submmal to tna Direcor_
Form 1824 (804)
Mail Application To Application No ______
New Mexico Environment Department Air Quality Bureau New Source Review Unit 2048 Galisteo AIRS No ____________ Santa Fe NM 87505
Phone (505) 827-1494 For NMED use onlyhttpwwwnmenvstatenmus
Air Quality Permit Application And Notice Of Intent Universal (General) to Construct or Modify
Acknowledgement x I acknowledge that a pre-application meeting is available to me upon request
X Permit filing fee enclosed Check No S 1~ CO lt
Part I - General Information I-A Company Information
I Company name University of California for the US Department of Energy Date application notarized 12ltgt 0 t
2 Facility name Los Alamos National Laboratory SIC code (4 digits) 9711
3 Companymailing address Meteorology and Air Quality Group PO Box 1663 MS J978 Los Alamos NM 87545
4 Contact person Jean Dewart I Title Group Leader
5 Phone No 505-665-0239 IFax No 505-665-8858 IE-mail dewartlanlgov
I-B Current Facility Status
I This application is for (check one) New Facility X Modification to an existing facility or Revision
2 Has this facility already been constructed XYes ONo I Ifyes is it currently operating in New Mexico XYes ONo
3 Is the plant currently shut down DYes XNo I Ifyes give month and year of shut down (MMlYY) NA
4 Was this facility constructed before 1972 and operated since 1972 X Yes ONo
5 Does this facility have an operating permit under 20 NMAC 270 X Yes DNo If yes the permit No is P- 100
6 Has this facility been issued a No Permit Required (NPR) X Yes [No Ifyes the NPR number is 2195A
7 Has this facility been issued a Notice of Intent (NOl) X Yes ONo IUyes the NOI Number is 2597
8 Does this facility have a construction permit (20 NMAC 272 Section 200A or 200B) X Yes [No
bull Ifyes the permit No is 2195 2195-BM1 2195-F 2195-8
1
9 Has this facility been issued a general permit (GCP-I GCP-2 ) X Yes ONo I Ifyes the registration No is GCP3shy
2195G
10 Is this a major source under the PSD rules DYes X No OUnsure I Is this a major source under Title V (20 NMAC
bull 270) X Yes [No [Unsure I Is this a major modification under the PSD rules (20 NMAC 274) DYes X No OUnsure
11 If Yes or Unsure to any of the questions in question No 10 contact the AQB to see if a pre-application meeting is required
Rev 71802
Table ImiddotB Current Facility Status (continued)
12 What is the facilitys maximum input capacity specify units (reference here and list capacities in Attachment L if more room is required)
bull Current Hourly NfA Daily NfA Annually NfA
bull Proposed Hourly 6000 scf Daily 144000 set1 Annually 526 X 10 scf
13 What is the facilitys maximum production rate specify units (reference here and list capacities in Attachment L ifmore room is required)
bull Current Hourly NtA Daily NtA Annually Nt A
bull Proposed Hourly 6000 setl Daily 144000 set1 Annually 526 X 106scfl
Values are based on maximum capacity ohml vapor extraction system to extract 100 sefm of soli pore-gas for treatment
Table laC Facility Location Information
1 Section 36 IRange 6E ITownship 19N ICounty Los Alamos I Elevation (ft) 7400
2 UTM Zone 012 or X13 IUTMH (record to one tenth ofa Ian) 3869 IUTMV (record to one tenth of a Ian) 39664
OR Latitude (deg min sec) I Longitude (deg min sec)
3a Name and zip code of nearest New Mexico town Los Alamos 87544
3b Distance and Direction from nearest New Mexico town Approximately 5 miles southeast of Los Alamos
4 Detailed Driving Instructions from nearest NM town (attach a road map if necessary)
The facility is __5__ (distance) miles ___SE_ (direction) L Alamos (nearest town) with entrance offof Pajarito Road (road accessible to LANL bad2e holders only)
5 Status ofland at facility (check one) DPrivate llndiantPueblo X Government
6 Name ofnearest Class I area to the facility (see Figure 10) Bandelier Wilderness Area
7 Shortest distance from TA-54 boundary to the boundary of the nearest Class I area (record to one tenth ofa Ian) 55km
Table ImiddotD Proposed Operating Schedule (Note the operating schedule (D1 D2) shall become a condition oUhe permit)
I FT (hOursaCI tty maximum operatIng day) 24 I (days ) 7 week
I weeks(--) 52 year I hours(year ) 87fiO
2 Facilitys maximum daily operating schedule (ifless than 24 h~) Start NA IDAM IDPM End NA I DAM CPM
3 Month and year of anticipated start of construction April 2005
4 Month and year of anticipated construction completion April 2005
5 Month and year of anticipated startup of new or modified facility April 2005
6 Will this facility operate at this site for more than one year X Yes CNo (IfSVE system is selected remediation option)
Table 1-1 Other
1 Is this application in response to a Notice ofViolation (NOV) DYes X No
bull Ifyes NOV date NA INOV Tracking No NA
2 Is air quality dispersion modeling being submitted with this application DYes X No
3 Does this facility require an Air Toxics permit under 20 NMAC 272 Part IV Tables A andor B in Part V DYes X No
4 Will this facility be a source offederal Hazardous Air Pollutants X Yes ON0
bull Ifyes list applicable subparts in 40 CFR 61 amp 63 None
Rev 71802 2
Part II - Required Attachments
The following Attachments are required please label each accordingly A complete application shall include
Attachment A A process flow sheet andor block diagram indicating the individual equipment all emission points and types of control applied to those points Numbering system should cross reference with Attachment B
Attachment B A plot plan drawn to scale showing emissions points structures tanks and fences of property owned leased or under direct control of the applicant
Attachment C All calculations used to determine both the hourly and armual controlled and uncontrolled emission rates Reference where emission factors were obtained If identical units are being permitted and will be subject to the same operating conditions submit calculations for only one unit and a note specifying what other units the calculations represent
Attachment D Information Used to Determine Emissions bull If manufacturer data are used include specifications for emissions units and control equipment If test data are used include a copy of the complete test report If the test data are for an emissions unit other
than the one being permitted the emission units must be identical Test data may not be used if any difference in operating conditions ofthe unit being permitted and the unit represented in the test report significantly effect emission rates
bull If the most current copy of AP-42 is used reference the section and date located at the bottom of the page Include a copy of the page containing the emissions factors and clearly mark the factors used in the calculations
bull If an older version of AP-42 is used include a complete copy of the section bull If an EPA document or other material is referenced include a complete copy bull Fuel specifications sheet bull If computer models are used to estimate emissions include an input summary (if available) and a detailed
report and a disk containing the input file(s) used to run the model For tank-flashing emissions include a discussion of the method used to estimate tank-flashing emissions relative thresholds (ie permit or major source (NSpS PSD or Title V)) accuracy of the model the input and output from simulation models and software all calculations documentation of any assumptions used descriptions of sampling methods and conditions copies of any lab sample analysis
Attachment E A map such as a 7S minute topographic quadrangle showing the exact location of the source The map shall also middot ldthtlle 0 owmgmc u e The UTM or Longitudinal coordinate system on both axes An indicator showing which direction is north A minimum radius around the plant ofSkm (31 miles) The nearest occupied structure(s) Topographic features of the area Access and haul roads The name of the map Facility property boundaries A scale The area which will be restricted to public access
Attachment F Proof of public notice Include a copy of the certified letter receipts a list of the places where the public notice has been posted and (see guidance document)
a sample of the letters sent to land owners a sample and verification of the local po stings a sample of the letters sent to municipalities a copy of the display ad and its affidavit ofpublication a copy of the announcement sent to a local radio station a copy of the classified ad and its affidavit of
publication
Attachment G A written description of the routine operations of the facility Include a description of how each piece of equipment will be operated how controls will be used and the fate of both the products and waste generated For modifications andlor revisions explain how the changes will affect the existing process
Attachment H A PSD applicability determination for all sources For PSD major sources applying for a significant permit revision use the procedures for Determining the Net Emissions Change at a Source as specified by Table A-5 (Page A45) of the EPA New Source Review Workshop Manual to determine if the revision is subject to PSD review
Attachment I A discussion demonstrating compliance with each applicable state amp federal regulation If there is a state or federal regulation for your facilitys source category that does not apply to your facility explain why For example 40 CFR 60 Subpart 000 (crushers) 40 CFR 63 Subpart HHH (HAPs) or 20 NMAC 274 (PSD major sources)
Rev 711802 3
Attachment J A preliminary operational plan defining the measures to be taken to mitigate source emissions during malfunction startup or shutdown
Attachment K An air quality dispersion modeling demonstration (if applicable) as outlined in the Air Quality Bureaus Dispersion Modeling Guidelines
Attachment L Other relevant information Use this attachment to clarifY any part in the application that you think needs explaining Reference the section table column andor field
Submit the original signed and notarized copy of the application package and
1) One working copy for department use and 2) One copy if air dispersion modeling is included (include disks with input and output files) and 3) One copy ifpublic notice was required and 4) If subject to PSD review under 20 NMAC 274 (PSD) one copy for US EPA one copy for each federal land
manager affected (NPS USFS FWS USDl) and one copy for each affected regulatory agency other than the Air Quality Bureau
Rev 71802 4
Part III - Production and Control Equipment
Table III-A Regulated Equipment (Unit and stack numbering must correspond throughout the application package) Note If applying for a NOI under 20 NMAC 273 equipment exemptions under 272202 do not appi) and all equipment should be listed here
Manufacshyturer Model No
Date of Capacity Applicable Unit Manufacture Type (Specify For Each Piece of Equipment State Reg (s) ReplacingReconstruction No (MMDDIYY) Serial No (Source Description) Units) Check One 20 NMAC 2X Unit No
Catalytic 2027 NMAC CAT- Combustion
20261 NMAC OX-1
Corporation 100E o Existing (unchanged) o To be Removed X NewAdditional o Replacement Unit 20270 NMAC
2004 TBD Electric catalytic oxidizer 100 sefm o To be Modified [l To be Replaced 20273 NMAC NA
o Existing (unchanged) [l To be Removed n NewAdditional [1 Replacement Unit o To be Modified lJ To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit n To be Modified o To be Replaced
o Existing (unchanged) [J To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
[J Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit
Io To be Modified o To be Replaced
Rev 71802 5
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
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1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
I
Dec-17-200~ 054E~ From-LANL RRES r~ 5056658190 T-884 ~OOl001 F-843 0
~ ~ LosAlamos
TlO ~ ilOII TOI ---urn gt
SignatureReviewCoordination Sheet This form is to accompany all documents requinl9 review approval Or signature Dy G Peter Nanos Director
Deaoline lDate 121704 122004 I Is 11llS a response to an actIon Item Yes 0 No Iti From o Call for PICk-up
bull Name Kcn Hargis MS Name Pnone
TITLE loentTy coumem Dtlell) Oelicn)s 1080 matter Notice of Intent for the r A-54 MOA L Soil Vtpor Extraction ProjectI Action
o Information only BACKGROUNO
ISSUES
Ken needs [0 have Jackie ana Jean sign off bcforc hell Slsn etf
I ACTION requesliC of DirKtOr
OLD or ALe encorsement
Name (pnnr
CoordinateCS wj~h 1_ Name (pnm)
Jackje Hunk
2 Name (pMl)
Jean Dc art
3 Namamp (pnnl)
I 4 Name (prim) I
Signature
Signature
Signature Date
Please enSurE appropmlte tnte(intra DirectorateDlvJslonal coorOlnatJon anc reView pnor to submmal to tna Direcor_
Form 1824 (804)
Mail Application To Application No ______
New Mexico Environment Department Air Quality Bureau New Source Review Unit 2048 Galisteo AIRS No ____________ Santa Fe NM 87505
Phone (505) 827-1494 For NMED use onlyhttpwwwnmenvstatenmus
Air Quality Permit Application And Notice Of Intent Universal (General) to Construct or Modify
Acknowledgement x I acknowledge that a pre-application meeting is available to me upon request
X Permit filing fee enclosed Check No S 1~ CO lt
Part I - General Information I-A Company Information
I Company name University of California for the US Department of Energy Date application notarized 12ltgt 0 t
2 Facility name Los Alamos National Laboratory SIC code (4 digits) 9711
3 Companymailing address Meteorology and Air Quality Group PO Box 1663 MS J978 Los Alamos NM 87545
4 Contact person Jean Dewart I Title Group Leader
5 Phone No 505-665-0239 IFax No 505-665-8858 IE-mail dewartlanlgov
I-B Current Facility Status
I This application is for (check one) New Facility X Modification to an existing facility or Revision
2 Has this facility already been constructed XYes ONo I Ifyes is it currently operating in New Mexico XYes ONo
3 Is the plant currently shut down DYes XNo I Ifyes give month and year of shut down (MMlYY) NA
4 Was this facility constructed before 1972 and operated since 1972 X Yes ONo
5 Does this facility have an operating permit under 20 NMAC 270 X Yes DNo If yes the permit No is P- 100
6 Has this facility been issued a No Permit Required (NPR) X Yes [No Ifyes the NPR number is 2195A
7 Has this facility been issued a Notice of Intent (NOl) X Yes ONo IUyes the NOI Number is 2597
8 Does this facility have a construction permit (20 NMAC 272 Section 200A or 200B) X Yes [No
bull Ifyes the permit No is 2195 2195-BM1 2195-F 2195-8
1
9 Has this facility been issued a general permit (GCP-I GCP-2 ) X Yes ONo I Ifyes the registration No is GCP3shy
2195G
10 Is this a major source under the PSD rules DYes X No OUnsure I Is this a major source under Title V (20 NMAC
bull 270) X Yes [No [Unsure I Is this a major modification under the PSD rules (20 NMAC 274) DYes X No OUnsure
11 If Yes or Unsure to any of the questions in question No 10 contact the AQB to see if a pre-application meeting is required
Rev 71802
Table ImiddotB Current Facility Status (continued)
12 What is the facilitys maximum input capacity specify units (reference here and list capacities in Attachment L if more room is required)
bull Current Hourly NfA Daily NfA Annually NfA
bull Proposed Hourly 6000 scf Daily 144000 set1 Annually 526 X 10 scf
13 What is the facilitys maximum production rate specify units (reference here and list capacities in Attachment L ifmore room is required)
bull Current Hourly NtA Daily NtA Annually Nt A
bull Proposed Hourly 6000 setl Daily 144000 set1 Annually 526 X 106scfl
Values are based on maximum capacity ohml vapor extraction system to extract 100 sefm of soli pore-gas for treatment
Table laC Facility Location Information
1 Section 36 IRange 6E ITownship 19N ICounty Los Alamos I Elevation (ft) 7400
2 UTM Zone 012 or X13 IUTMH (record to one tenth ofa Ian) 3869 IUTMV (record to one tenth of a Ian) 39664
OR Latitude (deg min sec) I Longitude (deg min sec)
3a Name and zip code of nearest New Mexico town Los Alamos 87544
3b Distance and Direction from nearest New Mexico town Approximately 5 miles southeast of Los Alamos
4 Detailed Driving Instructions from nearest NM town (attach a road map if necessary)
The facility is __5__ (distance) miles ___SE_ (direction) L Alamos (nearest town) with entrance offof Pajarito Road (road accessible to LANL bad2e holders only)
5 Status ofland at facility (check one) DPrivate llndiantPueblo X Government
6 Name ofnearest Class I area to the facility (see Figure 10) Bandelier Wilderness Area
7 Shortest distance from TA-54 boundary to the boundary of the nearest Class I area (record to one tenth ofa Ian) 55km
Table ImiddotD Proposed Operating Schedule (Note the operating schedule (D1 D2) shall become a condition oUhe permit)
I FT (hOursaCI tty maximum operatIng day) 24 I (days ) 7 week
I weeks(--) 52 year I hours(year ) 87fiO
2 Facilitys maximum daily operating schedule (ifless than 24 h~) Start NA IDAM IDPM End NA I DAM CPM
3 Month and year of anticipated start of construction April 2005
4 Month and year of anticipated construction completion April 2005
5 Month and year of anticipated startup of new or modified facility April 2005
6 Will this facility operate at this site for more than one year X Yes CNo (IfSVE system is selected remediation option)
Table 1-1 Other
1 Is this application in response to a Notice ofViolation (NOV) DYes X No
bull Ifyes NOV date NA INOV Tracking No NA
2 Is air quality dispersion modeling being submitted with this application DYes X No
3 Does this facility require an Air Toxics permit under 20 NMAC 272 Part IV Tables A andor B in Part V DYes X No
4 Will this facility be a source offederal Hazardous Air Pollutants X Yes ON0
bull Ifyes list applicable subparts in 40 CFR 61 amp 63 None
Rev 71802 2
Part II - Required Attachments
The following Attachments are required please label each accordingly A complete application shall include
Attachment A A process flow sheet andor block diagram indicating the individual equipment all emission points and types of control applied to those points Numbering system should cross reference with Attachment B
Attachment B A plot plan drawn to scale showing emissions points structures tanks and fences of property owned leased or under direct control of the applicant
Attachment C All calculations used to determine both the hourly and armual controlled and uncontrolled emission rates Reference where emission factors were obtained If identical units are being permitted and will be subject to the same operating conditions submit calculations for only one unit and a note specifying what other units the calculations represent
Attachment D Information Used to Determine Emissions bull If manufacturer data are used include specifications for emissions units and control equipment If test data are used include a copy of the complete test report If the test data are for an emissions unit other
than the one being permitted the emission units must be identical Test data may not be used if any difference in operating conditions ofthe unit being permitted and the unit represented in the test report significantly effect emission rates
bull If the most current copy of AP-42 is used reference the section and date located at the bottom of the page Include a copy of the page containing the emissions factors and clearly mark the factors used in the calculations
bull If an older version of AP-42 is used include a complete copy of the section bull If an EPA document or other material is referenced include a complete copy bull Fuel specifications sheet bull If computer models are used to estimate emissions include an input summary (if available) and a detailed
report and a disk containing the input file(s) used to run the model For tank-flashing emissions include a discussion of the method used to estimate tank-flashing emissions relative thresholds (ie permit or major source (NSpS PSD or Title V)) accuracy of the model the input and output from simulation models and software all calculations documentation of any assumptions used descriptions of sampling methods and conditions copies of any lab sample analysis
Attachment E A map such as a 7S minute topographic quadrangle showing the exact location of the source The map shall also middot ldthtlle 0 owmgmc u e The UTM or Longitudinal coordinate system on both axes An indicator showing which direction is north A minimum radius around the plant ofSkm (31 miles) The nearest occupied structure(s) Topographic features of the area Access and haul roads The name of the map Facility property boundaries A scale The area which will be restricted to public access
Attachment F Proof of public notice Include a copy of the certified letter receipts a list of the places where the public notice has been posted and (see guidance document)
a sample of the letters sent to land owners a sample and verification of the local po stings a sample of the letters sent to municipalities a copy of the display ad and its affidavit ofpublication a copy of the announcement sent to a local radio station a copy of the classified ad and its affidavit of
publication
Attachment G A written description of the routine operations of the facility Include a description of how each piece of equipment will be operated how controls will be used and the fate of both the products and waste generated For modifications andlor revisions explain how the changes will affect the existing process
Attachment H A PSD applicability determination for all sources For PSD major sources applying for a significant permit revision use the procedures for Determining the Net Emissions Change at a Source as specified by Table A-5 (Page A45) of the EPA New Source Review Workshop Manual to determine if the revision is subject to PSD review
Attachment I A discussion demonstrating compliance with each applicable state amp federal regulation If there is a state or federal regulation for your facilitys source category that does not apply to your facility explain why For example 40 CFR 60 Subpart 000 (crushers) 40 CFR 63 Subpart HHH (HAPs) or 20 NMAC 274 (PSD major sources)
Rev 711802 3
Attachment J A preliminary operational plan defining the measures to be taken to mitigate source emissions during malfunction startup or shutdown
Attachment K An air quality dispersion modeling demonstration (if applicable) as outlined in the Air Quality Bureaus Dispersion Modeling Guidelines
Attachment L Other relevant information Use this attachment to clarifY any part in the application that you think needs explaining Reference the section table column andor field
Submit the original signed and notarized copy of the application package and
1) One working copy for department use and 2) One copy if air dispersion modeling is included (include disks with input and output files) and 3) One copy ifpublic notice was required and 4) If subject to PSD review under 20 NMAC 274 (PSD) one copy for US EPA one copy for each federal land
manager affected (NPS USFS FWS USDl) and one copy for each affected regulatory agency other than the Air Quality Bureau
Rev 71802 4
Part III - Production and Control Equipment
Table III-A Regulated Equipment (Unit and stack numbering must correspond throughout the application package) Note If applying for a NOI under 20 NMAC 273 equipment exemptions under 272202 do not appi) and all equipment should be listed here
Manufacshyturer Model No
Date of Capacity Applicable Unit Manufacture Type (Specify For Each Piece of Equipment State Reg (s) ReplacingReconstruction No (MMDDIYY) Serial No (Source Description) Units) Check One 20 NMAC 2X Unit No
Catalytic 2027 NMAC CAT- Combustion
20261 NMAC OX-1
Corporation 100E o Existing (unchanged) o To be Removed X NewAdditional o Replacement Unit 20270 NMAC
2004 TBD Electric catalytic oxidizer 100 sefm o To be Modified [l To be Replaced 20273 NMAC NA
o Existing (unchanged) [l To be Removed n NewAdditional [1 Replacement Unit o To be Modified lJ To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit n To be Modified o To be Replaced
o Existing (unchanged) [J To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
[J Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit
Io To be Modified o To be Replaced
Rev 71802 5
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
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SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
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4) u AlARIiI CONDmDNS ME ANNUNClAlED
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
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V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
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FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
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1000 1500 2000 2500 3000 3500 4000
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Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Mail Application To Application No ______
New Mexico Environment Department Air Quality Bureau New Source Review Unit 2048 Galisteo AIRS No ____________ Santa Fe NM 87505
Phone (505) 827-1494 For NMED use onlyhttpwwwnmenvstatenmus
Air Quality Permit Application And Notice Of Intent Universal (General) to Construct or Modify
Acknowledgement x I acknowledge that a pre-application meeting is available to me upon request
X Permit filing fee enclosed Check No S 1~ CO lt
Part I - General Information I-A Company Information
I Company name University of California for the US Department of Energy Date application notarized 12ltgt 0 t
2 Facility name Los Alamos National Laboratory SIC code (4 digits) 9711
3 Companymailing address Meteorology and Air Quality Group PO Box 1663 MS J978 Los Alamos NM 87545
4 Contact person Jean Dewart I Title Group Leader
5 Phone No 505-665-0239 IFax No 505-665-8858 IE-mail dewartlanlgov
I-B Current Facility Status
I This application is for (check one) New Facility X Modification to an existing facility or Revision
2 Has this facility already been constructed XYes ONo I Ifyes is it currently operating in New Mexico XYes ONo
3 Is the plant currently shut down DYes XNo I Ifyes give month and year of shut down (MMlYY) NA
4 Was this facility constructed before 1972 and operated since 1972 X Yes ONo
5 Does this facility have an operating permit under 20 NMAC 270 X Yes DNo If yes the permit No is P- 100
6 Has this facility been issued a No Permit Required (NPR) X Yes [No Ifyes the NPR number is 2195A
7 Has this facility been issued a Notice of Intent (NOl) X Yes ONo IUyes the NOI Number is 2597
8 Does this facility have a construction permit (20 NMAC 272 Section 200A or 200B) X Yes [No
bull Ifyes the permit No is 2195 2195-BM1 2195-F 2195-8
1
9 Has this facility been issued a general permit (GCP-I GCP-2 ) X Yes ONo I Ifyes the registration No is GCP3shy
2195G
10 Is this a major source under the PSD rules DYes X No OUnsure I Is this a major source under Title V (20 NMAC
bull 270) X Yes [No [Unsure I Is this a major modification under the PSD rules (20 NMAC 274) DYes X No OUnsure
11 If Yes or Unsure to any of the questions in question No 10 contact the AQB to see if a pre-application meeting is required
Rev 71802
Table ImiddotB Current Facility Status (continued)
12 What is the facilitys maximum input capacity specify units (reference here and list capacities in Attachment L if more room is required)
bull Current Hourly NfA Daily NfA Annually NfA
bull Proposed Hourly 6000 scf Daily 144000 set1 Annually 526 X 10 scf
13 What is the facilitys maximum production rate specify units (reference here and list capacities in Attachment L ifmore room is required)
bull Current Hourly NtA Daily NtA Annually Nt A
bull Proposed Hourly 6000 setl Daily 144000 set1 Annually 526 X 106scfl
Values are based on maximum capacity ohml vapor extraction system to extract 100 sefm of soli pore-gas for treatment
Table laC Facility Location Information
1 Section 36 IRange 6E ITownship 19N ICounty Los Alamos I Elevation (ft) 7400
2 UTM Zone 012 or X13 IUTMH (record to one tenth ofa Ian) 3869 IUTMV (record to one tenth of a Ian) 39664
OR Latitude (deg min sec) I Longitude (deg min sec)
3a Name and zip code of nearest New Mexico town Los Alamos 87544
3b Distance and Direction from nearest New Mexico town Approximately 5 miles southeast of Los Alamos
4 Detailed Driving Instructions from nearest NM town (attach a road map if necessary)
The facility is __5__ (distance) miles ___SE_ (direction) L Alamos (nearest town) with entrance offof Pajarito Road (road accessible to LANL bad2e holders only)
5 Status ofland at facility (check one) DPrivate llndiantPueblo X Government
6 Name ofnearest Class I area to the facility (see Figure 10) Bandelier Wilderness Area
7 Shortest distance from TA-54 boundary to the boundary of the nearest Class I area (record to one tenth ofa Ian) 55km
Table ImiddotD Proposed Operating Schedule (Note the operating schedule (D1 D2) shall become a condition oUhe permit)
I FT (hOursaCI tty maximum operatIng day) 24 I (days ) 7 week
I weeks(--) 52 year I hours(year ) 87fiO
2 Facilitys maximum daily operating schedule (ifless than 24 h~) Start NA IDAM IDPM End NA I DAM CPM
3 Month and year of anticipated start of construction April 2005
4 Month and year of anticipated construction completion April 2005
5 Month and year of anticipated startup of new or modified facility April 2005
6 Will this facility operate at this site for more than one year X Yes CNo (IfSVE system is selected remediation option)
Table 1-1 Other
1 Is this application in response to a Notice ofViolation (NOV) DYes X No
bull Ifyes NOV date NA INOV Tracking No NA
2 Is air quality dispersion modeling being submitted with this application DYes X No
3 Does this facility require an Air Toxics permit under 20 NMAC 272 Part IV Tables A andor B in Part V DYes X No
4 Will this facility be a source offederal Hazardous Air Pollutants X Yes ON0
bull Ifyes list applicable subparts in 40 CFR 61 amp 63 None
Rev 71802 2
Part II - Required Attachments
The following Attachments are required please label each accordingly A complete application shall include
Attachment A A process flow sheet andor block diagram indicating the individual equipment all emission points and types of control applied to those points Numbering system should cross reference with Attachment B
Attachment B A plot plan drawn to scale showing emissions points structures tanks and fences of property owned leased or under direct control of the applicant
Attachment C All calculations used to determine both the hourly and armual controlled and uncontrolled emission rates Reference where emission factors were obtained If identical units are being permitted and will be subject to the same operating conditions submit calculations for only one unit and a note specifying what other units the calculations represent
Attachment D Information Used to Determine Emissions bull If manufacturer data are used include specifications for emissions units and control equipment If test data are used include a copy of the complete test report If the test data are for an emissions unit other
than the one being permitted the emission units must be identical Test data may not be used if any difference in operating conditions ofthe unit being permitted and the unit represented in the test report significantly effect emission rates
bull If the most current copy of AP-42 is used reference the section and date located at the bottom of the page Include a copy of the page containing the emissions factors and clearly mark the factors used in the calculations
bull If an older version of AP-42 is used include a complete copy of the section bull If an EPA document or other material is referenced include a complete copy bull Fuel specifications sheet bull If computer models are used to estimate emissions include an input summary (if available) and a detailed
report and a disk containing the input file(s) used to run the model For tank-flashing emissions include a discussion of the method used to estimate tank-flashing emissions relative thresholds (ie permit or major source (NSpS PSD or Title V)) accuracy of the model the input and output from simulation models and software all calculations documentation of any assumptions used descriptions of sampling methods and conditions copies of any lab sample analysis
Attachment E A map such as a 7S minute topographic quadrangle showing the exact location of the source The map shall also middot ldthtlle 0 owmgmc u e The UTM or Longitudinal coordinate system on both axes An indicator showing which direction is north A minimum radius around the plant ofSkm (31 miles) The nearest occupied structure(s) Topographic features of the area Access and haul roads The name of the map Facility property boundaries A scale The area which will be restricted to public access
Attachment F Proof of public notice Include a copy of the certified letter receipts a list of the places where the public notice has been posted and (see guidance document)
a sample of the letters sent to land owners a sample and verification of the local po stings a sample of the letters sent to municipalities a copy of the display ad and its affidavit ofpublication a copy of the announcement sent to a local radio station a copy of the classified ad and its affidavit of
publication
Attachment G A written description of the routine operations of the facility Include a description of how each piece of equipment will be operated how controls will be used and the fate of both the products and waste generated For modifications andlor revisions explain how the changes will affect the existing process
Attachment H A PSD applicability determination for all sources For PSD major sources applying for a significant permit revision use the procedures for Determining the Net Emissions Change at a Source as specified by Table A-5 (Page A45) of the EPA New Source Review Workshop Manual to determine if the revision is subject to PSD review
Attachment I A discussion demonstrating compliance with each applicable state amp federal regulation If there is a state or federal regulation for your facilitys source category that does not apply to your facility explain why For example 40 CFR 60 Subpart 000 (crushers) 40 CFR 63 Subpart HHH (HAPs) or 20 NMAC 274 (PSD major sources)
Rev 711802 3
Attachment J A preliminary operational plan defining the measures to be taken to mitigate source emissions during malfunction startup or shutdown
Attachment K An air quality dispersion modeling demonstration (if applicable) as outlined in the Air Quality Bureaus Dispersion Modeling Guidelines
Attachment L Other relevant information Use this attachment to clarifY any part in the application that you think needs explaining Reference the section table column andor field
Submit the original signed and notarized copy of the application package and
1) One working copy for department use and 2) One copy if air dispersion modeling is included (include disks with input and output files) and 3) One copy ifpublic notice was required and 4) If subject to PSD review under 20 NMAC 274 (PSD) one copy for US EPA one copy for each federal land
manager affected (NPS USFS FWS USDl) and one copy for each affected regulatory agency other than the Air Quality Bureau
Rev 71802 4
Part III - Production and Control Equipment
Table III-A Regulated Equipment (Unit and stack numbering must correspond throughout the application package) Note If applying for a NOI under 20 NMAC 273 equipment exemptions under 272202 do not appi) and all equipment should be listed here
Manufacshyturer Model No
Date of Capacity Applicable Unit Manufacture Type (Specify For Each Piece of Equipment State Reg (s) ReplacingReconstruction No (MMDDIYY) Serial No (Source Description) Units) Check One 20 NMAC 2X Unit No
Catalytic 2027 NMAC CAT- Combustion
20261 NMAC OX-1
Corporation 100E o Existing (unchanged) o To be Removed X NewAdditional o Replacement Unit 20270 NMAC
2004 TBD Electric catalytic oxidizer 100 sefm o To be Modified [l To be Replaced 20273 NMAC NA
o Existing (unchanged) [l To be Removed n NewAdditional [1 Replacement Unit o To be Modified lJ To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit n To be Modified o To be Replaced
o Existing (unchanged) [J To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
[J Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit
Io To be Modified o To be Replaced
Rev 71802 5
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
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EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Table ImiddotB Current Facility Status (continued)
12 What is the facilitys maximum input capacity specify units (reference here and list capacities in Attachment L if more room is required)
bull Current Hourly NfA Daily NfA Annually NfA
bull Proposed Hourly 6000 scf Daily 144000 set1 Annually 526 X 10 scf
13 What is the facilitys maximum production rate specify units (reference here and list capacities in Attachment L ifmore room is required)
bull Current Hourly NtA Daily NtA Annually Nt A
bull Proposed Hourly 6000 setl Daily 144000 set1 Annually 526 X 106scfl
Values are based on maximum capacity ohml vapor extraction system to extract 100 sefm of soli pore-gas for treatment
Table laC Facility Location Information
1 Section 36 IRange 6E ITownship 19N ICounty Los Alamos I Elevation (ft) 7400
2 UTM Zone 012 or X13 IUTMH (record to one tenth ofa Ian) 3869 IUTMV (record to one tenth of a Ian) 39664
OR Latitude (deg min sec) I Longitude (deg min sec)
3a Name and zip code of nearest New Mexico town Los Alamos 87544
3b Distance and Direction from nearest New Mexico town Approximately 5 miles southeast of Los Alamos
4 Detailed Driving Instructions from nearest NM town (attach a road map if necessary)
The facility is __5__ (distance) miles ___SE_ (direction) L Alamos (nearest town) with entrance offof Pajarito Road (road accessible to LANL bad2e holders only)
5 Status ofland at facility (check one) DPrivate llndiantPueblo X Government
6 Name ofnearest Class I area to the facility (see Figure 10) Bandelier Wilderness Area
7 Shortest distance from TA-54 boundary to the boundary of the nearest Class I area (record to one tenth ofa Ian) 55km
Table ImiddotD Proposed Operating Schedule (Note the operating schedule (D1 D2) shall become a condition oUhe permit)
I FT (hOursaCI tty maximum operatIng day) 24 I (days ) 7 week
I weeks(--) 52 year I hours(year ) 87fiO
2 Facilitys maximum daily operating schedule (ifless than 24 h~) Start NA IDAM IDPM End NA I DAM CPM
3 Month and year of anticipated start of construction April 2005
4 Month and year of anticipated construction completion April 2005
5 Month and year of anticipated startup of new or modified facility April 2005
6 Will this facility operate at this site for more than one year X Yes CNo (IfSVE system is selected remediation option)
Table 1-1 Other
1 Is this application in response to a Notice ofViolation (NOV) DYes X No
bull Ifyes NOV date NA INOV Tracking No NA
2 Is air quality dispersion modeling being submitted with this application DYes X No
3 Does this facility require an Air Toxics permit under 20 NMAC 272 Part IV Tables A andor B in Part V DYes X No
4 Will this facility be a source offederal Hazardous Air Pollutants X Yes ON0
bull Ifyes list applicable subparts in 40 CFR 61 amp 63 None
Rev 71802 2
Part II - Required Attachments
The following Attachments are required please label each accordingly A complete application shall include
Attachment A A process flow sheet andor block diagram indicating the individual equipment all emission points and types of control applied to those points Numbering system should cross reference with Attachment B
Attachment B A plot plan drawn to scale showing emissions points structures tanks and fences of property owned leased or under direct control of the applicant
Attachment C All calculations used to determine both the hourly and armual controlled and uncontrolled emission rates Reference where emission factors were obtained If identical units are being permitted and will be subject to the same operating conditions submit calculations for only one unit and a note specifying what other units the calculations represent
Attachment D Information Used to Determine Emissions bull If manufacturer data are used include specifications for emissions units and control equipment If test data are used include a copy of the complete test report If the test data are for an emissions unit other
than the one being permitted the emission units must be identical Test data may not be used if any difference in operating conditions ofthe unit being permitted and the unit represented in the test report significantly effect emission rates
bull If the most current copy of AP-42 is used reference the section and date located at the bottom of the page Include a copy of the page containing the emissions factors and clearly mark the factors used in the calculations
bull If an older version of AP-42 is used include a complete copy of the section bull If an EPA document or other material is referenced include a complete copy bull Fuel specifications sheet bull If computer models are used to estimate emissions include an input summary (if available) and a detailed
report and a disk containing the input file(s) used to run the model For tank-flashing emissions include a discussion of the method used to estimate tank-flashing emissions relative thresholds (ie permit or major source (NSpS PSD or Title V)) accuracy of the model the input and output from simulation models and software all calculations documentation of any assumptions used descriptions of sampling methods and conditions copies of any lab sample analysis
Attachment E A map such as a 7S minute topographic quadrangle showing the exact location of the source The map shall also middot ldthtlle 0 owmgmc u e The UTM or Longitudinal coordinate system on both axes An indicator showing which direction is north A minimum radius around the plant ofSkm (31 miles) The nearest occupied structure(s) Topographic features of the area Access and haul roads The name of the map Facility property boundaries A scale The area which will be restricted to public access
Attachment F Proof of public notice Include a copy of the certified letter receipts a list of the places where the public notice has been posted and (see guidance document)
a sample of the letters sent to land owners a sample and verification of the local po stings a sample of the letters sent to municipalities a copy of the display ad and its affidavit ofpublication a copy of the announcement sent to a local radio station a copy of the classified ad and its affidavit of
publication
Attachment G A written description of the routine operations of the facility Include a description of how each piece of equipment will be operated how controls will be used and the fate of both the products and waste generated For modifications andlor revisions explain how the changes will affect the existing process
Attachment H A PSD applicability determination for all sources For PSD major sources applying for a significant permit revision use the procedures for Determining the Net Emissions Change at a Source as specified by Table A-5 (Page A45) of the EPA New Source Review Workshop Manual to determine if the revision is subject to PSD review
Attachment I A discussion demonstrating compliance with each applicable state amp federal regulation If there is a state or federal regulation for your facilitys source category that does not apply to your facility explain why For example 40 CFR 60 Subpart 000 (crushers) 40 CFR 63 Subpart HHH (HAPs) or 20 NMAC 274 (PSD major sources)
Rev 711802 3
Attachment J A preliminary operational plan defining the measures to be taken to mitigate source emissions during malfunction startup or shutdown
Attachment K An air quality dispersion modeling demonstration (if applicable) as outlined in the Air Quality Bureaus Dispersion Modeling Guidelines
Attachment L Other relevant information Use this attachment to clarifY any part in the application that you think needs explaining Reference the section table column andor field
Submit the original signed and notarized copy of the application package and
1) One working copy for department use and 2) One copy if air dispersion modeling is included (include disks with input and output files) and 3) One copy ifpublic notice was required and 4) If subject to PSD review under 20 NMAC 274 (PSD) one copy for US EPA one copy for each federal land
manager affected (NPS USFS FWS USDl) and one copy for each affected regulatory agency other than the Air Quality Bureau
Rev 71802 4
Part III - Production and Control Equipment
Table III-A Regulated Equipment (Unit and stack numbering must correspond throughout the application package) Note If applying for a NOI under 20 NMAC 273 equipment exemptions under 272202 do not appi) and all equipment should be listed here
Manufacshyturer Model No
Date of Capacity Applicable Unit Manufacture Type (Specify For Each Piece of Equipment State Reg (s) ReplacingReconstruction No (MMDDIYY) Serial No (Source Description) Units) Check One 20 NMAC 2X Unit No
Catalytic 2027 NMAC CAT- Combustion
20261 NMAC OX-1
Corporation 100E o Existing (unchanged) o To be Removed X NewAdditional o Replacement Unit 20270 NMAC
2004 TBD Electric catalytic oxidizer 100 sefm o To be Modified [l To be Replaced 20273 NMAC NA
o Existing (unchanged) [l To be Removed n NewAdditional [1 Replacement Unit o To be Modified lJ To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit n To be Modified o To be Replaced
o Existing (unchanged) [J To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
[J Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit
Io To be Modified o To be Replaced
Rev 71802 5
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
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Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
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TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Part II - Required Attachments
The following Attachments are required please label each accordingly A complete application shall include
Attachment A A process flow sheet andor block diagram indicating the individual equipment all emission points and types of control applied to those points Numbering system should cross reference with Attachment B
Attachment B A plot plan drawn to scale showing emissions points structures tanks and fences of property owned leased or under direct control of the applicant
Attachment C All calculations used to determine both the hourly and armual controlled and uncontrolled emission rates Reference where emission factors were obtained If identical units are being permitted and will be subject to the same operating conditions submit calculations for only one unit and a note specifying what other units the calculations represent
Attachment D Information Used to Determine Emissions bull If manufacturer data are used include specifications for emissions units and control equipment If test data are used include a copy of the complete test report If the test data are for an emissions unit other
than the one being permitted the emission units must be identical Test data may not be used if any difference in operating conditions ofthe unit being permitted and the unit represented in the test report significantly effect emission rates
bull If the most current copy of AP-42 is used reference the section and date located at the bottom of the page Include a copy of the page containing the emissions factors and clearly mark the factors used in the calculations
bull If an older version of AP-42 is used include a complete copy of the section bull If an EPA document or other material is referenced include a complete copy bull Fuel specifications sheet bull If computer models are used to estimate emissions include an input summary (if available) and a detailed
report and a disk containing the input file(s) used to run the model For tank-flashing emissions include a discussion of the method used to estimate tank-flashing emissions relative thresholds (ie permit or major source (NSpS PSD or Title V)) accuracy of the model the input and output from simulation models and software all calculations documentation of any assumptions used descriptions of sampling methods and conditions copies of any lab sample analysis
Attachment E A map such as a 7S minute topographic quadrangle showing the exact location of the source The map shall also middot ldthtlle 0 owmgmc u e The UTM or Longitudinal coordinate system on both axes An indicator showing which direction is north A minimum radius around the plant ofSkm (31 miles) The nearest occupied structure(s) Topographic features of the area Access and haul roads The name of the map Facility property boundaries A scale The area which will be restricted to public access
Attachment F Proof of public notice Include a copy of the certified letter receipts a list of the places where the public notice has been posted and (see guidance document)
a sample of the letters sent to land owners a sample and verification of the local po stings a sample of the letters sent to municipalities a copy of the display ad and its affidavit ofpublication a copy of the announcement sent to a local radio station a copy of the classified ad and its affidavit of
publication
Attachment G A written description of the routine operations of the facility Include a description of how each piece of equipment will be operated how controls will be used and the fate of both the products and waste generated For modifications andlor revisions explain how the changes will affect the existing process
Attachment H A PSD applicability determination for all sources For PSD major sources applying for a significant permit revision use the procedures for Determining the Net Emissions Change at a Source as specified by Table A-5 (Page A45) of the EPA New Source Review Workshop Manual to determine if the revision is subject to PSD review
Attachment I A discussion demonstrating compliance with each applicable state amp federal regulation If there is a state or federal regulation for your facilitys source category that does not apply to your facility explain why For example 40 CFR 60 Subpart 000 (crushers) 40 CFR 63 Subpart HHH (HAPs) or 20 NMAC 274 (PSD major sources)
Rev 711802 3
Attachment J A preliminary operational plan defining the measures to be taken to mitigate source emissions during malfunction startup or shutdown
Attachment K An air quality dispersion modeling demonstration (if applicable) as outlined in the Air Quality Bureaus Dispersion Modeling Guidelines
Attachment L Other relevant information Use this attachment to clarifY any part in the application that you think needs explaining Reference the section table column andor field
Submit the original signed and notarized copy of the application package and
1) One working copy for department use and 2) One copy if air dispersion modeling is included (include disks with input and output files) and 3) One copy ifpublic notice was required and 4) If subject to PSD review under 20 NMAC 274 (PSD) one copy for US EPA one copy for each federal land
manager affected (NPS USFS FWS USDl) and one copy for each affected regulatory agency other than the Air Quality Bureau
Rev 71802 4
Part III - Production and Control Equipment
Table III-A Regulated Equipment (Unit and stack numbering must correspond throughout the application package) Note If applying for a NOI under 20 NMAC 273 equipment exemptions under 272202 do not appi) and all equipment should be listed here
Manufacshyturer Model No
Date of Capacity Applicable Unit Manufacture Type (Specify For Each Piece of Equipment State Reg (s) ReplacingReconstruction No (MMDDIYY) Serial No (Source Description) Units) Check One 20 NMAC 2X Unit No
Catalytic 2027 NMAC CAT- Combustion
20261 NMAC OX-1
Corporation 100E o Existing (unchanged) o To be Removed X NewAdditional o Replacement Unit 20270 NMAC
2004 TBD Electric catalytic oxidizer 100 sefm o To be Modified [l To be Replaced 20273 NMAC NA
o Existing (unchanged) [l To be Removed n NewAdditional [1 Replacement Unit o To be Modified lJ To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit n To be Modified o To be Replaced
o Existing (unchanged) [J To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
[J Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit
Io To be Modified o To be Replaced
Rev 71802 5
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment J A preliminary operational plan defining the measures to be taken to mitigate source emissions during malfunction startup or shutdown
Attachment K An air quality dispersion modeling demonstration (if applicable) as outlined in the Air Quality Bureaus Dispersion Modeling Guidelines
Attachment L Other relevant information Use this attachment to clarifY any part in the application that you think needs explaining Reference the section table column andor field
Submit the original signed and notarized copy of the application package and
1) One working copy for department use and 2) One copy if air dispersion modeling is included (include disks with input and output files) and 3) One copy ifpublic notice was required and 4) If subject to PSD review under 20 NMAC 274 (PSD) one copy for US EPA one copy for each federal land
manager affected (NPS USFS FWS USDl) and one copy for each affected regulatory agency other than the Air Quality Bureau
Rev 71802 4
Part III - Production and Control Equipment
Table III-A Regulated Equipment (Unit and stack numbering must correspond throughout the application package) Note If applying for a NOI under 20 NMAC 273 equipment exemptions under 272202 do not appi) and all equipment should be listed here
Manufacshyturer Model No
Date of Capacity Applicable Unit Manufacture Type (Specify For Each Piece of Equipment State Reg (s) ReplacingReconstruction No (MMDDIYY) Serial No (Source Description) Units) Check One 20 NMAC 2X Unit No
Catalytic 2027 NMAC CAT- Combustion
20261 NMAC OX-1
Corporation 100E o Existing (unchanged) o To be Removed X NewAdditional o Replacement Unit 20270 NMAC
2004 TBD Electric catalytic oxidizer 100 sefm o To be Modified [l To be Replaced 20273 NMAC NA
o Existing (unchanged) [l To be Removed n NewAdditional [1 Replacement Unit o To be Modified lJ To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit n To be Modified o To be Replaced
o Existing (unchanged) [J To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
[J Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit
Io To be Modified o To be Replaced
Rev 71802 5
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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V2
~~ I -
~ l-------~- we - - __ J
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Part III - Production and Control Equipment
Table III-A Regulated Equipment (Unit and stack numbering must correspond throughout the application package) Note If applying for a NOI under 20 NMAC 273 equipment exemptions under 272202 do not appi) and all equipment should be listed here
Manufacshyturer Model No
Date of Capacity Applicable Unit Manufacture Type (Specify For Each Piece of Equipment State Reg (s) ReplacingReconstruction No (MMDDIYY) Serial No (Source Description) Units) Check One 20 NMAC 2X Unit No
Catalytic 2027 NMAC CAT- Combustion
20261 NMAC OX-1
Corporation 100E o Existing (unchanged) o To be Removed X NewAdditional o Replacement Unit 20270 NMAC
2004 TBD Electric catalytic oxidizer 100 sefm o To be Modified [l To be Replaced 20273 NMAC NA
o Existing (unchanged) [l To be Removed n NewAdditional [1 Replacement Unit o To be Modified lJ To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit n To be Modified o To be Replaced
o Existing (unchanged) [J To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
[J Existing (unchanged) o To be Removed o NewAdditional [J Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit
Io To be Modified o To be Replaced
Rev 71802 5
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Table III-B 20 NMAC 272 202B Exempted Equipment (If exempt under 20 NMAC 272 20285 list emission rates in Table IV-A) (Unit and stack numbering must correspond throughout the application package) Note This table is applicable only if applying for a 20 NMAC 272 permit Exemptions under 20 NMAC 272 202 do not apply to facilities requesting a NO under 20 NMAC 273 See application form instructions and Exemptions Procedure for instructions on this form
Manufac- Site Specific turer Model No 20NMAC
Date of Capacity 272202 Other Unit Mfg Type (Specify For Each Piece of Equipment Check Exemption Required No (MMffiDNYl Serial No (Source Description) Units) One (eg 272202B5) Information
o Existing (unchanged) o To be Removed NA o NewAdditional o Replacement Unit
o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
o Existing (unchanged) o To be Removed o NewAdditional o Replacement Unit o To be Modified o To be Replaced
6
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Table III-C Emissions Control Equipment (Additional Information) (Unit and stack numbering must correspond throughout the application ackage)
Unit Controlling Emissions Estimation No Control Equipment Description Controlled Pollutant(s) for Unit(s) No Control by Wei2ht Method
Volatile hydrocarbons EPA NA
---shyElectric catalytic oxidizer (VOC and HAP) CAT-OX-l 95-99 Vendor
------shy ---shy
Note The unit is itself a control device -----shy
------shy ---shy ~~~--
---shy
---shy
~-~ ~-~
bull
~~~--
---shy
-----shy ------shyc-~~~~- ---shy
I
Only list control equipment for TAPs if the TAPs PER is over its respective threshold ~s listed in 20 NMAC 272 Subpart V Tables A and B
7
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
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V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
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20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
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1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Part IV bull Emission Calculations
Table IV-A Unit Emissions Rates List Toxic Air Pollutants (TAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application package) Include tank-flashing emissions estimates Jlotential emission mte (PER)l Potential to emit (PTEz
o Lead o Lead TSP PMIO NOx CO VOC SOx o HzS TSP PMI0 NOx CO VOC SOx o HzS
Unit Iblhr lbfhr Iblhr lblhr lbfhr Ibfhr Iblhr lbfhr lblhr Iblhr Ibfhr Iblhr Iblhr Ibfhr
No tonlvr tonfvr tooyr tonyr tooyr tonyr tonyr tonfyr tooyr toovr tonvr tonvr toofvr tonyr
CAT-none none none none 76 none none none none none none 76 none none
OX-I none none none none 17 none none none none none none 17 none none
--------shy
i
Totals 76 76 ~
17 17 (PER) or Potential Emission Rate means the emission rate ofa source at its maximum capacity to emit a regulated air contaminant under its physical and operational design provided any physical or operational limitation
on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours ofoperation or on the type or amount of material combusted stored or processed shall be treated as part of its physical and operational design only if the limitation or the effect it would have on emissions is enforceable by the Department pursuant to the Air Quality Control Act or the federal Act 2 (PTE) or Potential to emit means the maximum capacity of a stationary source to emit a regulated air contaminant under its physical and operational design Any physical or operational limitation on the capacity of the source to emit a regulated air contaminant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted stored or processed shall be treated as part of its design if the limitations or the effect it would have on emissions is federally enforceable Secondary emissions do not count in determining the potential to emit of a stationary source 20 NMAC 272 300E PTE does include reductions in emissions due to federally enforceable limits
8
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Table IV-B Stack Exit and Fugltlve1 Emission (PTE) Rates for Pollutants and Stack Exit Conditions List Toxic Air Pollutants (TAPs) and Hazardous Air Pollutaftts (HAPs) In Table IV-C (Unit and stack numbering must correspond throughout the application Qackage) Include tank-flashing emissions estimates
Stack Exit Emission Rates for Criteria PoUutants Stack Exit Conditions (Not Applicable for Fugitives) Height
n Lead Orientation Above Moisture Inside TSP PMI0 NOx CO VOC SOx U H2S (HHorizontal Ground Flow Rate by Volume Diameter Iblhr Iblhr Ibhr Iblhr Ibhr Ibhr Ibhr VVertical) (ft) (acfm) () or
Stack Unit No(s) from Rain Caps Temp Velocity LxW No Table III-A tonlyr tonyr tonlyr tonyr tonyr tonyr tonyr (Yes or No) (F) (dscfm) (ftlsec) (ft)
none none none none 76 none none V 12 129 TBD S-1 CAT-OX-I 05
none none none none 17 none nonemiddot No 950 100 11
76 Totals ~
17
List all fugitives that are associated with the normal routine or non-emergency operation of the facility
9
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Tabl IY-C Stack exit Eml_lon Ratbullbull for HAP and TAP (Describe Stack Exit Conditions in Table IV-S) (Unit and stack numbering must correspond throullhout the application Dackage) Include tank-flashing emissions estimates
SDe(lifv the name of the HAP or TAP as It appears In Sedlon 112 (b) of the 1990 CAM or 20 NMAC 271 SubDart V In the SDa(le I rovlded below
HAPO TAP 0 HAP 0 TAP 0 HAPCJ TAp 0 HAPD TAP 0 HAPD TAP 0 HAPOTAPO HAP 0 TAP 0 HAPD TAro Stack Ibhr lbhr lblhr Iblhr Ibhr Iblhr Iblhr lblhr No Unit No(s) tonvr tonyr touyr tontyr tontvr tontVr tonvr tonvr
Note Emission estimates are shown In Attachment C for HAP and TAPs Maximum uncontrolled emissions are 51 tpytotal HAP Maximum
S-l CAT-OX-l controlled emissions are 03 tpy total HAP All TAP maximum emission rates are below Sub art IV Iblhr thresholds
----shy ----shy ----shy
----shy
------shy----shy ---shy
f--------shy 1-shy ------shy ------shy --shy
-----shy---shy
---shy
------shy
-----shy
TOTAL ~ I -shy
Only list TAPs that have a PER greater than the threshold emission rate listed in 20 NMAC 272 Subpart V Tables A and B
10
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Part V - Fuel ------shy
Table V~~el Characteristics and Usage (Unit and stack numbering must correspond throughout the application package) Specify Units
Unit Lower No Fuel Type (No2 Diesel Natural Gas Coal bullbullbull) Heating Value Hourly Usage Annual Usage Sulfur 00 Ash
------shy ------shy
NA - electric power only ---------shy
---------shy
~-----
---------shy-------shy
bull
-------shy
bull
-----shy
--shy---------shy
11
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
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Rev 71802 17
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Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Part VI - Material Storage and Handling
Table VI-A Liquid Storage Datat (Use additional sheets if necessary) ~ (Unit and stack numbering must correspond throughout the application package) Include aoorooriate tank-flashinll modelinll inout data Use an addendum to this table for unlisted data catellories
Vapor Averaee Storaee Conditions Max Storal e Conditions
Liquid Molecular Temp- True Vapor Temp- True Vapor
Tank Density Weight erature Pressure erature Pressure
No Material Name Composition (Ihgal) (Ib(Ibmolraquo (oF) (psia) (oF) (psia)
NA shy no material storage or handling
I
If tank is to be used for storage of different materials list all the materials run the newest version of TANKS on each and use the material with the highest emission rate to determine PER and PTE
12
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
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_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Table VI-B Liquid Storage Tank Data (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application package) Include annronriate tank-flashing modeling irrnut data Use an addendum to this table for unlisted data categories
Date Color Annual Installed Roof Seal Capacity Vapor (Table VI-C) Paint Through Turn-
Tank Modified Type Type Diameter Space Condition -put overs No (MMYY) Materials Stored (Table VI-C) (Table VI-C) (bbl) (M3
) (M) (M) Roof Shell (Table VI-C) (2aIlyr) per year
N A - no storage tanks
Table VI-C Liquid Storage Tank Data Codes
Roof TVDe Seal TVDe Welded Tank Seal TYDe Seal Type Riveted Tank Seal Type Roof Shell Color Paint Condo
FX Fixed Roof I Mechanical Shoe Seal 2 Liauid-mounted resilient seal 3 Vaoor-mounted resilient seal 4 Seal Tvoe WH White Good
IF Internal FloatinJ Roof A Primarv only A Primary only A Primarv only A Mechanical shoe orimarv only AS Aluminum (soecular) Poor
EF External FloatinJ Roof B Shoe-mounted secondary B Weather shield B Weather shield B Shoe mounted secondary AD Aluminum (diffuse)
P Pressure C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary C Rim-mounted secondary LG Liht Gray
MG Medium Gray
BL Black
10159 M3 = 420 gal = 100 bbl OT Other
13
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
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Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Table VImiddotD aat~rlaltsProcessed and Produced (Use additional sheets ifnec~ssary)
Material Processed Material Produced
Chemical Quantity
Description Composition Phase (specify units) Description
NA treatment of soil pore-gas only
---------shy
Chemical
Composition Phase Quantity I
(s~ecifl units
lG =Gas L = Liquid or S Solid
14
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
-------
Part VII- Emissions Measurement
Table VIImiddotA Continuous Emissions Measurement (CEM) Equipment (Use additional sheets if necessary) (Unit and stack numbering must correspond throughout the application packa e)
Stack Averaging
No
Sample
Pollutant(s) Range Sensitivity AccuracyManufacturer Model No Serial No Frequency Time
No Continuous Emissions Measurement Equipment (CEMs) required or proposed
Note If CEM data will be used as part of a federally enforceable permit condition or used to satisfY the requirements of a state or federal regulation include a copy ofthe CEMs
manufacturer specification sheet in Attachment D
]5
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
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8
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9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
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~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
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Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
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DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
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1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
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Electric Catalytic Oxidizer General Arrangement
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V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
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IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
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TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Table VII-B Parametric Emissions Measurement Equipment (Use additional sheets if necessary)
(Unit and stack numbering must correspond throughout the application package)
Unit
No Parameterl Pollutant Measured
Location of
Measurement
Unit of
Measure
Acceptable
Ran2e
Frequency of
Maintenance
Nature of
Maintenance
Method of
Recordin2
Averaging
Time
No parametric emissions measurement required or proposed
16
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ~ J1l1day ofDcC - ~1 =~l-- upon my oath or affirmation before a notary of the State of
New Mexico
Signature Da~e
Jean Dewart Group Leader- ENV-MAQ Printed Name Title
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this ~6 day of Dlrfablr
My authorization as a notary of the State ofN~ew2Mexico--_________ expires on the
_~~2~4~_____ dayof ____~Ju~n~e___________ _~2~O~O~6______~
NotaryS Signature
Delilah Baldonado Notarys Printed Name
Dat~
OFFICIALS~ ~ Delilah Baldonado ( ) NOTARY PUBLIC ( ) STATEOfNEWtvjEXICO (
~Y5~l~J2i~-tJEt d
Rev 71802 17
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
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8
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9 Cnri5b~d
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4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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TOlERANCES
X bull 006 XX - 003
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L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Part VIII - Certification
Company Name University of California for the US Department of Energy
We Jean Dewart and Alison Dorries hereby certify that the information and data submitted in this application are
true and as accurate as possible to the best of my knowledge and professional expertise and experience
Signed this ZO day of OUAH1vc- 2tJoupon my oath or affirmation before a notary of the State of
New Mexico
~~Yn ~~r Signature
Jean Dewart Group Leader - ENV -MAO Printed Name Title
Signature Date
Alison Dorries Group Leader - ENV -ECR Printed Name Title
Scribed and sworn before me on this to day of DlCllhbU
My authorization as a notary of the State of~NuewM~ex~iltco~_________ expires on the
____=24~____ dayof ____~J~un~e~_____~ __~2=O=O=6___~
1d~oJm r Dafu
Delilah Baldonado Notarys Printed Name
OFFICIAL SEAL (
Delilah Baldonado ( NOTARY PUBLIC (
STATE OF NEW MEXICO (
~~Wi~_ (
Rev 71802 17
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8
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6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
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Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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V2
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
o Ferr rgtcl
8
bullRcswfU o
Arts-e
9 Cnri5b~d
fcbbs
Cl(~ss 1 Vi de ~ess reGsmiddot
Ire e ler~ Pell -lt Slln P dr~o PQrks
~j BQncie ET
4 Peces ~ Gil C
6 Fescue de Aohe 7 white 1ounton 8 SQl Ct~ ek 5 Co r~SbQCi ell vens N P
Meteo(oco]iCcl StC tCJs incJcc ed cy
2 J ltr
Figure 10
Rev 711802 18
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment A
Process Flow Sheet
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
MDA L Soil Vapor Extraction Process Flow
Air Emissions
Exhaust Stack
-
Electric SVE Extraction
Vacuum Extraction
Catalytic Oxidation
Well Treatment
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment B
Plot Plan
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
~~~~ I 140 ftgtlt I o9~~~la~~
Legend
0 Proposed SVE Wells
bull Disposal Shafts
------Hadius of ~nfluence= 140 ft~ 1 v1 20 ft C ontou r s ~w~1 pound~ ~ ~~ ~ ~ AI Dirt Roads
Paved Roads
-r----r Fences
~ Structures
gto~ MDA L
~+ D Disposal Pits
~
o
~ ~ I )
o 25 50 100 I I I I I I I
Feet Scale 11000
Projection Nev Mexico SPCS-3002 Datum NAD 83
SOURCE LANL RRES Oataba Modified By M Wald-Hopklns Map 10 SVE 1 Data 7fl104
1639500
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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V2
~~ I -
~ l-------~- we - - __ J
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment C
Emission Calculations
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
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V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
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FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
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1000 1500 2000 2500 3000 3500 4000
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Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Discussion of Emission Calculations
The soil vapor extraction (SVE) pilot test at Material Disposal Area (MDA) L will evaluate SVE as a soil remediation technology for the subsurface hydrocarbon contamination from past disposal practices SVE is a commonly-used method for treating soil contaminated with volatile hydrocarbons The SVE system will consist of extraction wells from which subsurface air contaminated with hydrocarbon vapors is drawn under vacuum to an electric catalytic oxidizer for treatment The vapor stream is passed through a catalyst bed which has a destruction efficiency of 95 to 99 for the hydrocarbon compounds present All emissions from the system are exhausted from the single stack of the catalytic oxidation unit Due to the negative pressure throughout the system there are no fugitive emissions or other point sources associated with the operation
Air emissions from SVE systems are dependent on the specific contaminants and their concentrations at a given remediation site LANL has conducted quarterly sampling of the contaminant plume at MDA L from 1997 until the present time Results of the soil pore-gas sampling show concentrations in the ppmv range or lower with a few exceptions the chlorinated hydrocarbons 111 - trichloroethane and trichloroethene have been measured in the 1000 ppmv range
Emission estimates are based on the results from the extensive quarterly sampling which has occurred The potentiallbyr emission ratesare based on the single maximum concentration measured during the quarterly sampling Potential tpy emission rates are based on the average of all quarterly concentrations measured It is reasonable to base worst-case short-term emissions on the maximum concentration of a compound ever measured to yield a conservative value However it is not reasonable fo base annual tpy emissions on this single value the average monitored value is more appropriate Using the appropriate measured ppmv concentration mass emissions were calculated using the Ideal Gas Law
Potential emission rates were also calculated assuming no destruction efficiency from the catalytic oxidation unit even though it will be operating continuously It is anticipated a permit under 20272 NMAC will not be required for the project which means operation of the catalytic oxidizer will not be an enforceable permit condition and credit from its operation cannot be used to lower estimated potential emissions
In addition to volatile hydrocarbon emissions HCl and HF will be emitted from the CI and F removed during the oxidation process Emission estimates for these hazardous air pollutants are based on information provided by the equipment vendor
As shown in the following tables estimated maximum potential (without controls) VOC emissions are 76 lbhr and 17 tpy Maximum potential (without controls) HAP emissions are estimated to be 268 lblhr and 51 tpy Uncontrolled HAP emission estimates are higher than VOC primarily because the highest compound measured (111
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
trichloroethane) is a HAP and not a VOC The tpy estimates assume the SVE system will run 8760 hryr (every hour ofthe year)
Maximum actual (with controls) emissions from the SVE system have been estimated using the lower end of the destruction efficiency range of 95 Maximum actual VOC emissions are estimated to be O4lblhr and 01 tpy Maximum actual HAP emissions are estimated to be 13 lbhr and 03 tpy
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
lDichloroeiFiane[1IDictlloroethane[12=j[dichloroethene[1 f~jI 5jchloroeihene[trans~f lni~hl-~~T-r~
~ ~-+-- --~~~Lmiddot middotmiddotmiddot~middot~-~I--middotmiddot-~~~=~-I
60297 64175 100414 110543 75middot285middotmiddotmiddotmiddotmiddot=~~]~o_~utane ______ ~_ gtLl11 _
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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V2
~~ I -
~ l-------~- we - - __ J
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 758E+OOl
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
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_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004
2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 fewatm(I bmole oR) R
49467 oR T 1 atm P
35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 500 F
mass (Ibmin) = PVValueMW
RT1E6
4Toxic air pollutant under 20272 NMAC Subpart IV Thresholds for these specific pollutants range from 667 Ibhr to 96 Ibhr
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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TOlERANCES
X bull 006 XX - 003
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L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA l SOil VAPOR EXTRACTION
momethane Chioroethane - Chioroform i Chloromethane iCyCiohexane 1CyclOhexanone rDjbromoethane[1~2f6ichiorOtienzene[12r-
16lchTorobenzene(1)i=r----middot nihl~~t-r--middot-middot-middotmiddot
IliUUUlilmiddot__t___
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
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Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
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TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Isooctane 0_lt bullbull--_~~~~~
=~~f~6_r~e=~~~~~_-=-----N--+H-----===-==j 1~9EEYJ~enzene Methanol M~Ey~y~19h~~6e rv1ehylgyltIJpound~IlIne 1J1etbYJIe1~Ile[~~] Methylpentane[3-] 1Napiiih~ifene bullbull___~ __lt__gt~ _~ ~~~A__~ ~+_~__ ~
Irl~ljee~~e_
Trichloroethene iTril11ethYlbenzene[124-] TrimethYibenzene[135-]
Vinyl acetate
iVi~xI9hI9fi~~ 1~yl~IleJr~t~lt__~ -- __ t__ o= ~~l- J ~ ~~_~~~~~+ ___~ middot~~~Imiddot __ ~middot~~
total
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Notes 1Value is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 3lbmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 featm(lbmoleoR) R 49467 oR T
1 atm P 35 degF
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
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-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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TOlERANCES
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
1()()414 110543 7647010 7664393 540841
Bromomethane Butanonet2J CarbonDlsujfide
middotmiddotCarbonTetrachloride
chfofo~~~~~adiene(l
Hexane Hydr~~~Iri~A~id4 Hyd~r~fluoriC Acidr
Isooctane Isopropyl benzene Methanol
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
total 268E+01
Notes 1Value is maximum concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol 31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100 cfm V
07302 ft3atm(lbmoleOR) R oR49467 T
1 atm P of35
Conservative Local atmospheric pressure is 076 atm Conservative Average White Rock Temperature is 50degF
mass (Ibmin) = PVValueMW RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
7647010
-omoform iBromomethane Buianone[2rmiddotiCarbon Olsulfide
t __ __~~_ _~
iCarbon Tetrachloride ChrorO1]buiadIene[2-f shyiChlOrcibenzene---- -
Chioroethane---
Hexane HydrochiorlcAcICfHydrofluoric Acid4-
Isooctane lsopropylbenzeneMeiha-nor-middotmiddot middotmiddot
-- -~--~--~-
-~~~~=~-==f-- ~=
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
VIILl~~middot-=-=~Lmiddot--- --1 middot----middotmiddotmiddotmiddot~-i~~-middotmiddotmiddot~~~middotmiddotmiddotmiddot~~~~~tmiddot-middot-~~~~=t- middot-middotmiddot-~middotI
XYlene[1frmiddotmiddotmiddotmiddot Xleh~I13j+ltyl~~~_e[i~~]
total
Notes
lValue is average concentration from soil pore gas sampling during 1997 - 2004 2Molecular weight of compound equal to Ib per Ib-mol
31bmin calculated using ideal gas law equation and following values
Value Units Parameter 100
07302
49467 1
35
cfm featmlbmoleoR)
OR
atm OF
V
R T P
Conservative Local atmospheric pressure is 076 atm middotmiddotConservative Average White Rock Temperature is 50degF
mass (Ibmin) = PmiddotVmiddotValuemiddotMW
RT1E6
4SVE vendor data for HCI and HF emission rates
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
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Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
VOC AND HAP EMISSION ESTIMATES MDA L SOIL VAPOR EXTRACTION
Emission Summary
Maximum Controlled Rate 04 1742 01 13 5063
Notes 1The maximum emission rate assuming no emission control system and operating 8760 hryr 2The maximum emission rate assuming minimal 95 control from catalytic oxidation unit and operating at 8760 hryr
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment D
Emissions Information
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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TOlERANCES
X bull 006 XX - 003
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
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20
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0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
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1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Vendor Emissions Information
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
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TOlERANCES
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
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Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
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Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Drewelow Remediation Equipment Inc DREA MINORITY WOMENT OWNED CERTIFIED SMALL BUSINESS ENTERPRISE WWWDRE-EQUIPCOM REAL PROJECT SOLUTIONSreg
Date December 08 2004
To
Kristi Beguin Ecologist Science and Engineering Associates Inc --a Subsidiary ofApogen Technologies-shy505-661-0289 kristibeguinapogentechcom 1350 Central Ave 3rd Floor Los Alamos NM 87544
From Michael J Smith Sr National BusinessDevelopment Manager Drewelow Remediation Equipment Inc 8509 Estrelita Drive Las Vegas Nevada 89128 Office (702) 255-5933 Cell (702) 526-3269 Fax (702) 255-2261 Email michaeljsmithsraolcom
Subject Los Alamos NM
Dear Ms Beguin
Based on the information you provided us the DRE Real Project Solutionreg recommended for your project is our Model 100scfm Electric Catalytic Oxidizer equipped with a special Catalyst designed to treat Chlorinated and Fluorinated VOC Compounds Since there are both chlorinated and fluorinated compounds in the process air stream the oxidation reaction across the catalyst will form HCI and HF from those compounds Using the source concentration data we calculated the number of moles of each chlorinated or fluorinated compound coming to the oxidizer For each compound the corresponding number of moles of either HCI or HF that would be produced is determined from the molecular formula The sum of these individual calculations was then converted from molar units of measure to poundshr ofHCI and HF
Compound destruction efficiencies are developed based on the specifications provided by the catalyst manufacturer The efficiencies reached are a product of the air flow through the catalyst and the amount of catalyst in the oxidizer This ratio known as the GHSV is determined by the manufacturer through laboratory evaluation of the catalyst on the compounds in question The process conditions were reviewed by the catalyst manufacturer and their recommendations regarding catalyst volume and operating temperatures are used by us when designing the oxidizer to meet the window of95-99 destruction
Ifyou have any questions regarding this proposal please contact me at 702-255-5933
Sincerely
Michael J Smith Sr Business Development Manager Drewelow Remediation Equipment Inc
Main Office Business Contact 1523 Sterling Court Michael J Smith Sr Escondido CA 92029 702-255-5933 Phone 760-546-6456 michaeljsmithsraolcom Fax 760-546-6476
Page 1 of 1 - Apogen Letter for DRE 187
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
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IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
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sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
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V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
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TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
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1000 1500 2000 2500 3000 3500 4000
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Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
For Halogenated Hydrocarbons
CHLORJNATEDIFL110RJNATED HYDROCARBONS
Chlorinated and fluorinated
ACTIVITY
The activity of vOCat 360PFC is JIllJCb higher tmmP~num and transition meIaI~ catalsts This activityS exhibited overs wide Il_~r
form primarily ~Ret iUld HF TIle fonnation 6rHCl~~bull )i preferred 0Cr Cl2 ~i(~ easy to scrub utdlJP and~centl havep minimal efk(ton~yst life
hydrocaJbons are emitted ftom a chlorinated and fluorinatedWide variety ofindustrial hydrocarbons3nd especially processes as well 8l many soil wbenbothmcpltllitin beremedialion and ground water samemiddotpn)ceSS suWtJ1Usclean-up operations Engdhards makes Vocat 3~ppe idcillfor
VOCat 350 HC caIal)Stmiddot basbecn mosthaJogenated~~used successfully for IIUll1Y years (0 streamsdestroy cbIorUuttedhydrocartx)Ds
Engclbard bas DOW deC1oped SELECI1VJiY
f()Qd 360 PFC cabdyst to d~ both Duorinattd and chlorinated When contJOlJiIlStheemiampsioos VOC compounds Unlike many other CBtalystS vOCat 360 PFC ~S==the pJOVk)esJUgh ac~hit) egtOeUenl fOrmation or~~products selectivity and OU1rrumding stability VOCal 360PltC caw is very reqilired for oxidUiog Ouorina1ed selective ~8 wiele JUSC of and chlOrinated hydrocarbons chlorinated IJDdftUorlftaled
hydlOC8lbon speCieS middotVocat360 PFC catalyst Willmiddot
Oxidation Of~luOf9hydroqarbons With VOCat360PFC
I i
100
90
80
70 -
60
Tempetat (C)
Enacllllfd seeb topsusaotnliabJc iIlf~~the COInpoWall pmpertiagtmdJ1lC oCits produds Mliccs and ~ lIowew aU JiIaldum IId~and ~ I1raquoIleOlJ Ctllllemingany produd ~laquopnKlCampIIoritsllClcdiou oruc providod AT NO CHARGE AND Will NO WARJlANTY OF ANY KIND AJIIIIIes aNliUljctilto ~~ 1_aud Conditioos ofS4lle 1Iicb are ICJIOdIICcd on tbcTe--me aide ofeacb ~ AU WR1tAIFS OF MERCUANTADlUTY A4D ~ESS OF PURPOSE ARE OIlCLlMED R~ ror any hnIactI aud FU-d~ liability includiag IhII1lOr fMICD1 ~II Iilnilcd a prltWidoo in ~hInl$ TemlS aId CoodruOM f)r8lhl ~ is POlIiab~ fill OJRSOquencilll iilcidew or 1ltJraquo01 Mtn~ Nothiq should be COI~ IIIi bull ~QII or indce1nootto ~ aD patcm No _1ItlpIion IiAA14 be tn 111111 IlIl safely or cn~untaI pOlCMiou IDCIIliUTCti
_ i~ oItIwClfhef1llClllUrCamp l1raquoI)naI be nqrinxt
EC-OOOO Rc 1102
TYPICAL PROCESS APPlICATIONS
VOCal 36OPFC is ~ly~~fi for 8 wide 8ricty M~pp1iCatiincluding
bull Cbemiail p~ bull Soilremtdi~1ior1 bull Groundwater tre8bneut
TP1CALOPERATING SPECIFICATIONS
Cell a(fometry PerjormtJIrCet
Engelhard COfpoRdlOli Hl1 Wood JwemJe IseUn NJ06830middot077(J Telephone 732-631middot9505 Fm 732-205-6146 Weh site wWIengelhardcom
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
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~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
EPA Emissions Information
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
EPA-600R-97-116 October 1997
AIR EMISSIONS FROM THE TREATMENT OF SOILS CONTAMINATED
WITH PETROLEUM FUELS AND OTHER SUBSTANCES
Prepared by
Bart Eklund Patrick Thompson
Adrienne Inglis Whitney Wheelessmiddot
William Horton Radian Corporation
8501 Mo-Pac Boulevard PO Box 201088
Austin Texas 78720-1088 and
Stephen Roe EH Peehan amp Associates Inc
2880 Sunrise Boulevard Suite 220
Rancho Cordova California 95742
EPA Contract No 68-D3-0035 Work Assignment II-92
EPA Project Officer
SusanA Thorneloe Atmospheric Protection Branch (MD-63)
Air Pollution Prevention and Control Division US Environmental Protection Agency
Research Triangle Park North Carolina 27711
Prepared for
Us Environmental Protection Agency Office of Air and Radiation
and Office of Research and Development
Washington DC 20460
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
temperatures above 10000P via a direct flame or a combustion chamber The method is applicable to a wide range of compounds and over a large range of concentrations It is not however widely used for SVE applications except for largeshyscale long-term cleanups Por the flame to be self-sustaining the VOC concentration needs to be at percent levels that may be above the lower explosive limit for the contaminant of concern Par lower VOC levels auxiliary fuel such as methane or propane must be added The cost of this fuel can be prohibitive The efficiency of the method is also affected by changes in the flow rate As the flow rate varies from design conditions the mixing and residence times in the incinerator will vary and decrease the destruction efficiency Design efficiency typically is 98 or higher
553 Catalytic Oxidation
Catalytic oxidation also called catalytic incineration is similar in design and operation to thermal incineration except that a catalyst is present that enhances combustion The catalyst is usually palladium or platinum in a metallic mesh ceramic honeycomb or catalyst-impregnated beads in a packed bed The catalyst allows destruction to occur at lower temperatures than for thermal incineration (6OO-9OO 0 P) There is therefore less auxiliary fuel required and commensurate lower fuel costs
Design efficiencies of 95 to 99 percent are typical The catalyst can be damaged by overheating so the air stream must be diluted if necessary to a VOC concentration below about 3000 ppmv to maintain acceptable operating temperatures Maintenance of this VOC level raises the capital and operating cost of the system since accurate monitoring of the gas stream
is needed as is the ability to control the dilution of the gas stream As for thermal incinerators catalytic oxidation systems function best when the flow rate is constant
The catalyst will become less effective over time and can be adversely affected by trace contaminants in the gas stream Depending on the type of catalyst employed it can be damaged by chlorinated hydrocarbons mercury phosphorus or heavy metals
554 Internal Combustion Engines (IC)
Industrial or automotive engines have been widely used to control VOC emissions from SVE systems Depending on the engine size air flows of 30 to 100 scfm have been treated The effective flow rate is reduced however if ambient air must be added to the air stream to add sufficient
oxygen to support combustion As with other thermal treatment methods supplemental fuel is needed
Destruction efficiencies of 99+ have been reported for the most common components of gasoline (Pedersen and Curtis 1991) Advantages of IC engines as controls are that the systems are portable they can handle very concentrated air streams without the need for dilution and the engine can provide power to operate the SVE system Disadvantages are that the systems can only treat small flow rates and that manual supervision is required for a period during start-up to set the flow rates and operating conditions Emissions of NOx from the engine may be a concern in some locales
555 Miscellaneous Control Approaches
5-9
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
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SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
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DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
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Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
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3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment E
Site Map
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment F
Proof of Public Notice
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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V2
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~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Proof of Public Notice
Public notice is not required for a Notice ofIntent application under 20273 NMAC
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment G
Project Description
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Project Description
LANL used Material Disposal Area (MDA) L from the early 1960s until 1985 as the designated disposal area for non-radiological containerized and uncontainerized liquid chemical wastes including chlorinated solvents Located at Technical Area (TA) 54 MDA L consists of an elongated pit three impoundments and 34 shafts Area L is the asphalted area atop MDA L and is currently used for RCRA-permitted chemical waste storage and treatment and for mixed waste storage under interim status authority All of the former disposal units are covered by asphalt andor chemical waste storage structures Subsurface vapor phase hydrocarbons were detected during the mid-l 980s and the existence of a hydrocarbon vapor plume was verified during the RCRA Phase I characterization ofMDA L Ongoing monitoring of the hydrocarbon plume is done through quarterly soil pore-gas sampling which has been conducted from 1995 to the present time These data show hydrocarbon concentrations exceeding 1000 ppmv near the source areas
A soil vapor extraction (SVE) pilot test at MDA L is proposed to evaluate both 1) the volume and rate ofplume reduction and 2) a means for determining and controlling any significant influx of the source (eg an increase in the liquid source caused by rupture of the buried drums) to assure the contaminant plume will not increase in size
SVE is an in situ unsaturated (vadose) zone soil remediation technology in which a vacuum is applied to the soil to induce the controlled flow of air and remove volatile contaminants from the soil For the pilot test proposed at MDA L the gas leaving the borehole will be treated to destroy the contaminants using a catalytic oxidation treatment unit Catalytic oxidation accelerates the rate ofoxidation by adsorbing the oxygen and the contaminants onto the catalyst surface where they react to form carbon dioxide water and hydrochloric and hydrofluoric gas The catalyst enables the oxidation reaction to occur at much lower temperatures (typically 6000 to 10000 F) than those required by a conventional thermal oxidation unit
Asphalt currently covers the entire MDA L area and retains vapors at or near the ground surface The efficiency of the extraction will be greatly enhanced by the asphalt cover The highest plume concentrations are located directly beneath the asphalt pad at MDA L Locating extraction wells beneath this cover will minimize the amount of surface air pulled into the extraction interval thus increasing the radial influence ofthe extraction system Locating the extraction boreholes in the central part of the contaminant plume will result in concentrations of the soil gas at all distances from the extraction interval to decrease with time
Two extraction wells are proposed for this pilot SVE project Extraction intervals will begin at 65 below ground surface (bgs) This depth is adjacent to the bottom of the disposal shafts (typically 60 deep) which will ensure that higher concentrations of contaminants are not pulled deeper into the soil while minimizing any short circuiting of the surface air to the extraction interval Contaminants at levels of concern extend to
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
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-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
depths of approximately 300 bgs therefore the extraction intervals will be extended to a depth of 215 bgs
The anticipated operating sequence of the SVE system includes short extraction and rebound intervals at the two extraction wells followed by longer duration extraction and rebound periods Initial short extraction times will confinn the absence ofa free liquid source and minimize gross scale movement of the plume The SVE system will be connected to each of the new extraction wells in tum and will run for short periods of time (on the order of days or weeks depending on how quickly monitoring port concentrations respond with a reduction in measured values) The system will then be turned off and the concentration rebound at the ports will be monitored Once the short duration periods are completed longer extraction times will be perfonned Extraction at each of the wells will be conducted until measured concentrations within the area of influence have been significantly reduced
The SVE equipment to be used during the MDA L SVE pilot test is a Model 100E electric catalytic oxidizer manufactured by Catalytic Combustion Corporation and owned and serviced by Drewelowe Remediation Equipment Inc This unit is an integrated vapor extraction and treatment system and contains a Sutorbilt Model3L-Legend P 100 scfm dry vacuum blower The catalyst will be specifically designed to treat chlorinated and fluorinated hydrocarbon compounds and will be manufactured by Engelhard Corporation The catalytic oxidation unit will be directly connected to the vapor extraction wells using standard plumbing fittings and piping The unit will be require 110220 volt line power which will be connected by a licensed electrician
The process description is as follows The vapor stream is pulled from the extraction well and is blown through a duct system that contains a vaporliquid separator a flame arrestor a heat exchanger an electric heater and a catalyst bed The vapor stream is preheated with the electric heater in order to reach the temperature necessary to initiate the catalytic oxidation of the hydrocarbons The preheated hydrocarbon-laden stream is then passed through the bed of catalysts where the hydrocarbons are rapidly oxidized and finally the stream is discharged to the exhaust stack Destruction efficiencies of hydrocarbons using catalytic oxidation are typically 95 to 99
As described above initial use ofthe SVE system is limited to a pilot study However if selected as part of the final remedy for the site future use of the system may be more extensive and long-tenn For this reason this application and associated hours of operation and emission estimates are based on continuous operation at 8760 hours per year
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment H
middotPSD Applicability Determination
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
PSD Applicability Determination
LANL is a minor source with respect to the PSD permit program Modifications to LANL such as the SVE Project would have to be a major source in and of themselves in order to trigger PSD applicability The major source threshold for the SVE Project is a potential to emit of 250 tpy of any PSD pollutant The potential to emit for the SVE Project is 17 tpy VOe PSD review does not apply to this project
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment I
Regulatory Applicability and Compliance
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Regulatory Applicability and Compliance
The analysis in this attachment describes the applicability of pertinent air quality regulations to the proposed project and compliance with those regulations which will apply
2027 NMAC - Excess Emissions During Malfunction Startup Shutdown or Scheduled Maintenance In the event of any startup shutdown or malfunction which results in excess emissions LANL will comply with the notification requirements specified in Section 110 of the rule
20261 NMAC - Smoke and Visible Emissions This regulation applies to certain stationary combustion equipment which is defined in the rule as any stationary device or system used to oxidize solid liquid or gaseous materials The catalytic oxidation unit will oxidize soil pore-gas containing ppmv levels of hydrocarbon compounds The rule requires visible emissions from the unit to be less than an opacity of 20 Exhaust gas from the catalytic oxidation unit which is electric powered will be in compliance with the 20 opacity limit
20270 NMAC - Operating Permits LANL was issued a final Title V operating permit on April 30 2004 Modifications to LANL other than small actions deemed insignificant activities must be included in the Title V operating permit once new source review permitting is completed The proposed soil vapor extraction (SVE) process has estimated maximum annual emissions of 17 tpy VOC and 5l tpy HAP (see Attachment C) Thus estimated emissions are above the 10 tpy threshold in the NMEDs List of Insignificant Activities for VOCs and HAPs
Since the SVE Project does not qualify as an insignificant activity a revision to the Title V permit is required As defined under 20270 NMAC the revision will be a significant permit modification This Notice ofIntent application will undergo preconstruction permit review which means under 20270 NMAC LANL will file the Title V permit revision for the SVE Project within twelve months from the date the project commences operation
Emissions from the SVE process are subject to all facility-wide emission limits in the LANL Title V permit including the 24 tpy limit for HAPs As reported in the LANL 2003 emission inventory report to NMED total HAP emissions from LANL sources were 108 tpy Additional HAP emissions from the SVE process will not impact the facility-wide HAP limit
20272 NMAC - Construction Permits The applicability of 20272 NMAC is specified at Section 200 of the rule Subsections A (I) and (2) require construction permits for new or modified sources which have a potential emission rate exceeding specified thresholds for regulated air contaminants for which there is a National or New Mexico Ambient Air Quality Standard The SVE
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
process will emit VOCs and HAPs only Ambient air quality standards are not established for HAPs Likewise there are no ambient air quality standards for VOCs NMED requires permits for major sources ofVOCs under other permit regulations which do not apply to the proposed project but does not currently do so for the minor source new source review program under 20272 NMAC Therefore a permit is not required for the project under these subsections
Subsection A(3) requires permits for new or modified sources subject to New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) or any other New Mexico regulation which contains emission limitations for any regulated air contaminant The SVE process will not be subject to any NSPS NESHAP or other regulation with a specified emission limit for any air contaminant which will be emitted
Subsection A(4) references the applicability of Subpart IV of20272 NMAC for toxic air pollutants Subpart IV requires a permit if the potential emissions of a toxic pollutant exceeds the specified lblhr threshold in Section 502 of the rule As described in Attachment C of this application emissions from the SVE process may include eight toxic air pollutants However as shown in Attachment C potentiallbhr emissions are below the permit threshold for each compound Note also that Subpart IV does not apply to a new source which is uniquely defined to include any new source which is integrally related with and integrally connected to an existing source MDA L is an existing source under this Subpart (constructed prior to December 31 1988) and the SVE system by its nature will be integrally related and connected to MDA L Thus Subpart IV would not apply to the SVE Project regardless of the lblhr emission rates of any toxic air pollutant
Subsection A(5) requires a permit for new or modified sources which emit greater than 5 tpy of lead This subsection does not apply to the project
Subsection A(6) references the federal requirements for permits for major sources of hazardous air pollutants which previously were in 20283 NMAC (now rescinded) but which are now incorporated by reference in 20282 NMAC These requirements implement Section 112(g) of the federal Clean Air Act and are in 40 CFR Part 60 Subpart B Under these requirements a permit is required if a new process or production unit at a developed site in and of itself has the potential to emit 10 tpy of anyone HAP or 25 tons of total HAP As shown in Attachment C emissions from the SVE process have a potential to emit of 51 tpy of total HAP (taking no credit for reduced emissions from the catalytic oxidation unit) This subsection does not require permitting ofthe SVE system
In summary a construction permit is not required for the proposed project under 20272 NMAC
20273 NMAC - Notice ofIntent and Emission Inventory Requirements This regulation requires a Notice of Intent application prior to construction ofa new stationary source which has a potential emission rate greater than 10 tpy of any regulated
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
air contaminant It also requires an application for any modification to an existing stationary source when either prior to or after the modification the source has a potential emission rate greater than 10 tpy of any regulated air contaminant Regulated air contaminant means any compound for which emissions or ambient concentration is regulated under the New Mexico of federal Clean Air Acts
The SVE process has the potential to emit many individual VOCs and HAPs as shown in Attachment C The total potential VOC emissions are 17 tpy Total potential HAP emissions are estimated to be 51 tpy This application is intended to fulfill the requirement of20273 NMAC to file a Notice ofIntent prior to the start of construction
20273 NMAC also requires submittal of annual emission inventory to NMED by April I of each year LANL submits this report each year and will continue to do so
20277 NMAC New Source Performance Standards This rule adopts the federal NSPS requirements at 40 CFR Part 60 by reference There are no NSPS requirements which would apply to the SVE process
20278 NMAC -Emission Standards for Hazardous Air Pollutants This rule adopts the federal NESHAP requirements at 40 CFR Part 60 by reference There are no NESHAP requirements which would apply to the SVE process
20282 NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air Pollutants This rule adopts the federal Maximum Achievable Control Technology (MACT) standards for source categories of HAPs by reference as well as the general provisions in 40 CFR Part 63 None of the general provision requirements or source category MACT standards would apply to the SVE process
EPA has promulgated a final MACT standard at 40 CFR Part 63 Subpart GGGGG for site remediation activities However among other applicability criteria this standard only applies to facilities which are defined as a major source of HAPs LANL is and will continue to be with the addition of the SVE process a minor HAP source subject to the facility-wide HAP limit of 24 tpy in the Title V permit The rule also exempts site remediations which will be performed under Resource Conservation and Recovery Act (RCRA) corrective action provisions The remediation ofMDA L is under RCRA corrective action requirements In addition the initial pilot study using the SVE system which may ultimately be the only time the system it used is an evaluation of the technology and not an activity which meets the definition of site remediation in the rule Subpart GGGGG will not apply to the SVE system
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment J
Operational Plan for Startup Shutdown or Malfunction
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Operational Plan for Startup Shutdown or Malfunction
TA-S4 is currently operated under a series of operating procedures to ensure the protection of safety and health and the environment Operation of the soil vapor extraction system will be in accordance with manufacturers specifications which will minimize air emissions from the catalytic oxidation unit during startups shutdowns or malfunctions The most current LANL operating procedures are available for review upon request
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment K
Dispersion Modeling
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Dispersion Modeling
Dispersion modeling is not required for a Notice of Intent under 20273 NMAC For a source which only emits YQCs dispersion modeling is also not required under 20272 NMAC
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Attachment L
Additional Information
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Electric Catalytic Oxidizer P amp ID
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
--OXIDIZE QPElt1ON 12_
1) DURING SYSTEIoI STARUP lHE DlUJIION AIR SOlENOID VAlVE (SV1) IS HELD OPEN FOR PURCE AND HEAlUP MANUAl VAlVE (VI) SHOULD BE F1ILLY OPEN 2) NTER lHE CATNST INlET TDIPEIIAllJRE SET POIKT (SYSTEIoI RUOI) IS REACHED (SV1) IS ApoundIEASED TO OPEHaDSE AIR FlOW BASED ON
=A~~=~~(V~~ERMBE SLOWLY (TDIPERAllJRE RISE) ACROSS THE CATAlST
~ (SV1) IS CONtROUED sr THE EXOlHERM REACIION CMISED sr THE cilllIIUSnllpoundS IEINC 0l0DIZED THROUGH THE CATNST NS THE CATAlST OUIpoundT TDIPEIIAME RISES THE INCREASIIIG DlUJIION AIR LOiIERS THE COWIIUSIlIII CONCEN1RA1ION IIEING OXIDIZED AND LOiIERS THE CATAlST OUIpoundT InIfIERAI1JR
4) IF THE CATAlST OUIpoundT TDIPEIIAltJRE RISES NKNE THE HIGH LAlIT str POIKT THE UNIT WILL BE SHUTIlOWNbull
IUlCllEIEIIIDI
-I I I I I
IllWi 1) FOR COIoIPONENT 1NIOIIIM1ION AND WIRING DETAILS
SEE poundIEClR1CAl SIHlMIlCS
2) CATAlST IlRpound OF TOTAl IDOl
~ VTlIITIES - 230-VACIJOHzPH
4) u AlARIiI CONDmDNS ME ANNUNClAlED
3 pound-sTDP
HIS 10 I I 3
I~I - DIllE I IWATl
I I IWEIGHT
TOlERANCES
X bull 006 XX - 003
JOO( - 0015 l bull 05
~--_ lIlT
V2
~~ I -
~ l-------~- we - - __ J
-shy I I I I I I I
-
L ~~-_ I_I==~ ----------------------shy ~ ~ ~I~
sect CATALYTIC COMBUSTION
DATE ICUSTOMER ~2r= CorporatIon I 9-22-04 APOGEN TECHNOLOGIES INC a-- WI 54724
ToIeph_ 715-588-2882 Fax 715-5118-2884
catoIytIooombullloncom
SCALE
NONE DRAWN BY
1mtE ELECTRIC CATALYTIC OXIDIZER
PampID
GU I _NO IRET I-1h~=ltrEC1M I 040500 500 0 A
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Electric Catalytic Oxidizer General Arrangement
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
--
-
Ifshy
V 100E CATALYTIC OXIDIZER01
LC J -shy
BELT GUARD ~ ] i-- SITE TUBE WITH V EXHAUST
STACK~ HIGH-HIGH lEVELSWITCH
FLOW ELEMENT
IV ~W IN~CATOR 3- PROCESS INLET 12 FT AGL
AIR SOUNOrO ACCESS flAME ___ V ARRESTOR - ~ ~ -
MANlW DlWTION ~~ 0 ~ ~ I Crw-AIR VALVE 1- 74 12- ~ ~ i( (i lUi a bullbull T ~
r H ~ ~ ~li I-- 1------0
ILI II (0) II I--~ I cJ C J cJ cJ cJ cJ I
FORKUFT POCKETS 72 96I II EXHAUST SILENCER - VA~R UQUIOPROCESS BLOWER SEPARATOR WITHPO TYPE APPROXIMATE wt 2700 LBS5 HP 230V 3 PH 15 GALLON CAPACITY
TEFC MOTOR- (SUTORBILT 3L)
II(lIlY CUSTOMERMATL DATE APOGEN TECHNOLOGIES INC - 9-22-04- sect
SCALEWEIGHT
- TITlENONEEeJ toLlfTd~ 100E ELECTRIC CATALYTIC OXIDIZER TOIERANCES DRAWN BY7011 - 21 Awn Bloomer WIeconeIn 54724 GENERAL ARRANGEMENT x - 006
T__ 715-518-2l1li2 FAX 715-1118-2884 GU
DRAWING-=a 1HE IIOIIIIUmDH IIEIIlIM bull 1HE PROIIIIIY OF CATILYIIC PROJECTPRODUCT REV SIZE ~10~ IW USE EIICEPI _ FeR liIICH COIIUSIDI OORP IIIIHOUt WRImN - IW IXlPINOXX bull 003
CHECKED BYxxx - 0015 l - 05 100040500 AINCH [mm] DO NOT SCAl THIS DRAWING 0
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Sutorbilt Vacuum Pump Specifications
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Date 9132004 PROJECT
tIII Sutor6IIt7 Application Customer Name Comments
Application Engineer Sales Order Number
GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP SERVICE Dry Vacuum
CORRECTED VALUES ORIGINAL UNITS Inlet Set 1 Altitude 7450000 Alt (ft) Barometer 11154 PSIA Inlet Pres -80000 InH20(G) Inlet Temp 6800 F Inlet Flow 10000 scm Dis Pres 15000 In H20 (G) Rel Humid 360 Delta Pressure 95000 InH20(G)
MEASURED VALUES PLOT UNITS Inlet Set 1 Blower Speed 2289 RPM of Max Speed 636 Blower Power 41 HP Efficiency 578 Discharge Temp 1465 F Estimated Noise 797 dBA
Drive losses not included
GAS PARAMETERS ENGLISH UNITS Inlet Set 1 MOlecular Weight 2886 lbmlbmol R Value 5356 ftlbflbmR Density 0042 lbmft3 Sp Heat Const P 0242 BTUlbmR Ratio of Sp Heats 140 Saturated Vapor Pres 34024 PSIA Partial Pres of Gas 81441 PSIA Partial Pres of Vapor 01220 PSIA
METRIC UNITS
2886 kgkgmol 029 kJkgK
0673 kgm3 1 011 kJkgK 140
02346 Bars(A) 05615 Bars(A) 00084 Bars(A)
Page 1 Gardner Denver Inc GDSmartPik tm - V 1061
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
Date 911312004 PROJECT Sutorbllt GAS MIXTURE Air(lOO) MACHINE SELECTION 3L-LegendP
90-LL
Q) f)
800 ci E Q)
I shy 70
60~------~--------~~--~~~--~~~~--~~--~--~
1000 1500 2000 2500 3000 3500 4000
-2 LL U ~ 3 0u
60
-a J 50 - shyQ)
3 0 40a
30
20
150
100
50
0 1000 1500 2000 2500 3000 3500 4~000
70 ~-_~ __ bull__ -l __ - shy 1 ------~--
-----shy
1000 1500 2000 2500 3000 3500 4000
Speed (RPM)
Page 2 Gardner Denver Inc GDSmartPik tm - V 1061
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA
1 OF 1
INVOICE NO DATE DESCRIPTION DISCOUNT NET AMOUNT
ACTS187-1 - - 12162004 PERMT SVE MDAL TAS4 SOOOO
CHECK NO DATE VENDOR NO VENDOR NAME TOTAL AMOUNT
S3386 12172004 AC0604401 NEW MEXICO ENVIRONMENT DEPT SOOOO
THE FACE OF THIS CHECK IS PRINTED BLUEmiddot THE BACK CONTAINS A SIMULATED WATERMARK
CHECK NO LOS ALAMOS NATIONAL LABORATORY 53386 53386 UNIVERSITY OF CAUFORNIA
POBox 1663 MSP240 Los AlamosNM 87545
Pay Five hundred and 00100 Dollars MO DAY YR
To 121704 $SOOOO
The flEASE CASH fROMfTL Y
Order NEW MEXICO ENVIRONMENT DEPT SUBJECT TO CANCELLATlON NINETY (90) DAYS AFTER DATE
Of AIR QUALITY BUREAU 2048 GALISTEO ST SANTA FE NM 87S0S
WELLS FARGO BANK OHIO NA