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Energy and Environment Directorate
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Staff Accomplishments

Keeping the DOE complex in compliance with air pollution requirements

August 2004
Pacific Northwest National Laboratory (PNNL) helps the U.S. Department of Energy (DOE) understand and comply with the federal regulations issued under the Clean Air Act. The act provides incentives and legal mandates for the private sector and government agencies to eliminate, reduce, and manage air pollutants. Outdoor air pollution can cause a variety of short-term health effects and can contribute to or aggravate chronic health conditions. At the request of DOE's Office of Air, Water, and Radiation Protection, Policy, and Guidance (EH-41), PNNL helps DOE respond to proposed changes to the regulations implementing the Clean Air Act and understand how the changes will affect DOE sites from Washington State to South Carolina. When a change is proposed to the regulations implementing the Clean Air Act, the Environmental Protection Agency (EPA) seeks comments from the public and government agencies by publishing the proposal in the Federal Register. PNNL frequently reviews and analyzes proposed rules issued under the Clean Air Act for DOE, and to consolidate comments from the DOE complex into one logical, consistent document. PNNL then sends the comment package, which can range from 2 to 60 pages, to DOE. In turn, DOE reviews the comments and submits them to EPA. "DOE wants their concerns and interests represented to EPA before the rule is final," said project manager Paul Hendrickson. "Often DOE concerns and interests are different than those of the private sector. For example, DOE often has facilities that contain radioactive materials, and these materials present occupational health hazards that need to be taken into account when new regulations are prepared." Because DOE operates a wide variety of sites, including research laboratories and incinerators, complying with new regulations can be complicated. "PNNL's scientific and technical experience is invaluable on this project," said Hendrickson. "Our experience helps us understand the activities at each site, from nuclear waste cleanup at Savannah River to incinerators at Oak Ridge." PNNL often provides concise guidance summaries of final rules issued under the Clean Air Act to assist in the compliance process. These summaries, which generally range from 2 to 25 pages, are typically posted on EH-41's website (http://homer.ornl.gov/oepa/) and e-mailed to the people responsible for regulatory compliance at each DOE site. The interrelated nature of the Clean Air Act makes it necessary to stop from time to time and take a broad view of the implementing regulations. For example, how do the Clean Air Act rules on vehicle fuels, a common source of air pollution, relate to each other? To answer this and similar questions, PNNL prepares guidance summaries on specific topics. These documents answer frequently asked questions about the topic, while connecting and summarizing the applicable regulations. Sifting through regulations, which are constantly updated, can be expensive, confusing, and tedious. Overlooking a regulation or misinterpreting how it applies, however, can have far greater consequences to DOE and to the environment and those that inhabit it. Product Line Manager: Diana Shankle, diana.shankle@pnl.gov, 509-372-4350 Project Manager: Paul Hendrickson, paul.hendrickson@pnl.gov or (509) 372-4294

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