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Clean Air Act: Title V Operating Permit LANL Application

Executive Summary

This permit application is submitted by Los Alamos National Laboratory (LANL or the Laboratory) for a Title V operating permit pursuant to 20.2.70 NMAC - Operating Permits. Title V of the federal 1990 Clean Air Act Amendments (CAAA) requires facilities defined as major stationary sources to obtain comprehensive air quality operating permits that include all air quality requirements applicable to the source. An operating permit is separate and in addition to air quality construction permits which are issued for new projects or modifications.

LANL submitted to the New Mexico Environment Department (NMED) an initial operating permit application for the Laboratory in December 1995. The NMED ruled the initial application complete in April 1996. However, since that time, the NMED has not completed the review and processing of the initial application. This application is a comprehensive update and replacement to the December 1995 application.

LANL is owned by the Department of Energy/National Nuclear Security Administration (DOE/NNSA) and operated by the University of California. The Laboratory is a nonprofit scientific institution dedicated to research and development (R & D) in nuclear weapons science and technology, and national problems in energy, environment, infrastructure and health security. With respect to air pollutant emissions, emissions predominately come from operations that support R & D activities, such as power and steam generation, rather than from R & D activities themselves. LANL is classified as a major stationary source under Part 70 and requires an operating permit primarily due to combustion of natural gas to provide power, steam, and comfort heat to the Laboratory.

With this application LANL is requesting facility-wide emission limits in order to ensure the Laboratory remains a minor stationary source for purposes of the Prevention of Significant Deterioration (PSD) construction permit program and the CAAA Title III requirements for hazardous air pollutants (HAPs). Information provided in Chapter 2 of the application shows that past actual emissions are below the major source thresholds for both PSD and the CAAA Title III. Chapter 3 of the application provides detailed information about regulated operations at LANL and proposes numerous limits to ensure facility-wide emissions stay below the PSD and CAAA Title III major source thresholds in the future.

The Laboratory worked closely with the NMED, Air Quality Bureau to structure the application so that it fulfills all the requirements of 20.2.70 NMAC for identifying applicable requirements and fees, and also provides for the operational flexibility needed for a research facility.

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