US D 1.6/2:C 73/5 A DEPARTMENT OF DEFENSE Commanding Officer's Guide for Compliance to the Clean Air Act Amendments Of 1990 • < Form Approved REPORT DOCUMENTATION PAGE OMB No. 0704-0188 Public reporttng burden for this collection of information •s esttmated to average 1 hour per response, including the time for reviewing instructions, searching existing data sources, gathenng and maintaining tt-le data needed. and completing and revtewtng the collectton of information. Send comments r~arding this burden estimate or any other aspect of this collection of information. including suggestions for reducing this burden. to Washtngton Headquarters Services. Directorate or Information Operations and Reports. 1215 Jefferson Davis Highway. Suite 1204. Arlington. VA 22202-4302. and to the Office of Management and Budget. Paperwork Reduction Project (0704·0 188). Washington. DC 20503. 1. AGENCY USE ONLY (Leave blank) ,2. REPORT DATE ,3. REPORT TYPE AND DATES COVERED September 1992 4. TITLE AND SUBTITLE 5. FUNDING NUMBERS A Department of Defense Conunanding Officer's Guide For Compliance to the Clean Air Act Amendments of 1990 6. AUTHOR(S) Martin G. Elliott Lisa M. Polyak 7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) 8. PERFORMING ORGANIZATION REPORT NUMBER u.s. Army Toxic & Hazardous u.s. Army Environmental Materials Agency Hygiene Agency CETHA-EC-TR-92060 Aberdeen Proving Ground, MD Aberdeen Proving Ground, 21010-5401 MD 21010-5422 10. SPONSORING I MONITORING AGENCY REPORT NUMBER 9. SPONSORING I MONITORING AGENCY NAME(S) AND ADDRESS(ES) The Department of Defense Services Steering Conunittee For Clean Air Act Implementation Room 654 Crystal Plaza 115 Arlington, VA 20350-2000 11. SUPPLEMENTARY NOTES 12a. DISTRIBUTION/AVAILABILITY STATEMENT 12b. DISTRIBUTION CODE 13. ABSTRACT (Maximum 200 words) i LOCKW0UU U:..:.; \J~•• I UNIVERSITY AT BUFFALO FEB i 9 1993 DOCUMENTS DEPOSITGrW LiBRARY 0433 14. SUBJECT TERMS 15. NUMBER OF PAGES Clean Air Act Amendments of 1990 20 Environmental Compliance Issues & Guidance 16. PRICE CODE 17. SECURITY CLASSIFICATION 18 . SECURITY CLASSIFICATION 19. SECURITY CLASSIFICATION 20. LIMITATION OF ABSTRACT OF REPORT OF THIS PAGE OF ABSTRACT Unclassified Unclassified NSN 7540-01 -2 80-5500 Standard Form 298 (Rev. 2-89) Prescnbed by ANSI Std . Z39·18 298·102 A DEPARTMENT OF DEFENSE Commanding Officer's Guide for Compliance to the Clean Air Act Amendments of 1990 September 1992 ~-Printed on Recycled Paper ·"· FOREWORD A Department of Defense Commanding Officer's Guide for Compliance to the Clean Air Act Amendments of 1990 This document was prepared as a joint effort between the U.S. Army Tox ic and Hazardous Materials Agency and the U.S. Army Environmental Hygiene Agency. It was prepared at the request and under the direction of the Department of Defense Services Steering Committee for Compliance to the Clean Air Act Amendments of 1990. It is hoped that this guide will help military installation commanding officers in supporting the ideals and goals of the Clean Air Act Amendments of 1990 and help eliminate a duplication of effort throughout the Services in achieving this end . ~,6,_ Thomas E. Baca Deputy Assistant Secretary of Defense (Environment) Air Quality Compliance Air quality compliance deals with the prevention , control and abatement of air pollution from stationary and mobile sources . Stationary sources typically include anything emitting air pollution from a fixed exhaust stack , like a heating boiler, incinerator or industrial manufacturing plant. Mobile sources include motor vehicles , aircraft and marine vessels. Most air pollution regulations are directly related to a human health impact, although odor prevention and visibility degradation may also be the driving element for some requirements. Since air is essentially an unconfined medium, air pollution problems often can be readily detected both on and off-base. Maintaining compliance with air quality regulations may require reduction or elimination of pollutant emissions from existing sources, as well as control of new pollution sources. The Clean Air Act Amendments of 1990 (CAA-90) represent the most recent legislation for the control of air pollution in the United States. These amendments are the first significant revisions to the Clean Air Act in 13 years. The new statute strengthens and broadens earlier legislation by setting specific goals and timetables for reducing urban smog, airborne toxics, acid rain, and stratospheric ozone depletion over the next decade and beyond. Those indust ries most heavily affected by the new Amendments include the chemical industry, automobile manufacturers, oil refineries, steel manufacturing plants, and the electric utility companies. Although Department of Defense (DOD) ins tallations are not specifically targeted by this legislation, they often contain many types of facilities that will be affected under the new law . These facilities will be subject to the same administrative, procedural and enforcement standards that any private bus iness would face and consequently, are faced with future significant increases in the resources needed to manage their air quality programs . CAA-90 contains eight major titles which address various aspects of the National Air Pollution Control Program . These titles are : Title I Attainment and Maintenance of National Ambient Air Quality Standards Title II Mobile Sources Title Ill Hazardous Air Pollutants Title IV Acid Deposition Con t rol Title V Permits Title VI Stratospheric Ozone Protection Title VII Enforcement Title VIII Miscellaneous Provisions Major impacts on DOD installations come from Titles I (Attainment) , Ill (Hazardous Air Pollutants), V (Permits), and VII (Enforcement). Areas Violating Ozone Standards Areas Violating Carbon Monoxide Standards Based on information available at the time of publication, a total of 41 areas fail to meet the national standard for carbon monoxide. This compares with 96 areas failing for ozone (top map) and 72 areas failing for particulate matter (not shown). TITLE I-AIR QUALITY REQUIREMENTS: Title I mandates technology-based emissions control for new and existing major air pollution sources. Title I also describes air pollution control requirements for geographic areas in the United States which fail to meet the National Ambient Air Quality Standards (NAAQS). The NAAQS are enforceable limits on the level of ozone, carbon monoxide, sulfur dioxide, nitrogen dioxide, inhalable particulate matter, and lead permitted in the outdoor air. Title I requires new types of emission controls in areas which fail to meet the ozone, carbon monoxide, and inhalable particulate matter NAAQS. Since ozone is currently the most pervasive nonattainment pollutant in the United States, most of Title I is directed at controlling pollutant emissions which contribute to ground-level ozone formation [i.e., volatile organic compounds (VOCs) and nitrogen oxides (NOx)]. IMPACTS: Military VOC sources typically affected by Tit le I include fuel storage and dispensing facilities, spray painting/coating lines, organic solvent degreasing operations, and dry cleaners. Affected military unique NOx sources include most types of combustion processes, such as open burning/open detonation sites, engine test cells, hazardous/municipal/medical waste incinerators, and fossil-fuel-fired steam/hot water boilers and explosives production lines. Major requirements will involve the preparation of emission inventories for regulated sources and ac quisition of emission control equipment for newly defined major sources of VOCs and NOx. TITLE Ill-HAZARDOUS AIR POLLUTANTS REQUIREMENTS: Title Ill also mandates technology-based emissions control for new and existing major air pollution sources. It is potentially the most pervasive and costly requirement of CAA-90 . The major elements of this Title deal with control of hazardous air pollutants (HAPs) from certain source categories and contingency planning for accidental releases of hazardous substances. 189 HAPs were identified in the new Amendments. IMPACTS: Affected HAP sources have to make process modifications and/or install control equipment to limit emissions and comply with maximum available control technology (MACT). Most of the VOC sources listed in Title I are also affected by Title Ill requirements. Emission levels must be verified according to regulations and quantified by either continuous emission monitoring, stack sampling, or estimation using EPA-approved emission factors. · The program will substantially decrease the number ofcancer cases caused by air pollution, and it will reduce many other health effects. Health Effects of Regulated Air Pollutants Criteria Pollutants Health Concerns Ozone Respiratory tract problems such as difficult breathing and reduced lung function. Asthma, eye irritation, nasal congestion, reduced resistance to infection, and possible premature aging of lung tissue. Particulate Matter Eye and throat irritation, bronchitis, lung damage; also impaired visibility. Carbon Monoxide Ability of blood to carry oxygen impaired; Cardiovascular nervous and pulmonary systems affected. Sulfur Dioxide Respiratory tract problems, permanent harm to lung tissue. Lead Retardation and brain damage, especially in children. Nitrogen Dioxide Respiratory illness and lung damage. Hazardous Air Pollutants Asbestos A variety of lung diseases, particularly lung cancer. Beryllium Primary lung disease, although Air Toxics: Technology Standards also affects liver, spleen, kid Will Drastically Cut Cancer Risks neys, and lymph glands. from Stationary Sources Mercury Several areas of the brain as well as the kidneys and bowels affected. Vinyl Chloride Lung and liver cancer. Arsenic Causes cancer. Radionuclides Causes cancer. 'iii E ,g Benzene Leukemia Ill ""' ·c: Coke Oven Emissions Respiratory Cancer. Q; (.) c rl Source: Meeting the Environmental Challenge: EPA's Review C1> .2: of Progress and New Directions in Environmental Protection :;Cii E ::J (Dec. 1990) . () 1990 2000 •MACT: Maximum Ach ievable Technology Standards TITLE V -PERMITS REQUIREMENTS: Title V establishes a nationwide permit program for air pollution sources. The goal of Title Vis to have states issue Federally enforceable operating permits for identified stationary sources. The permits are designed to enhance the ability of EPA, State regulatory agencies, and private citizens to monitor and enforce the requirements of CAA-90 . Permits will clarify operating and control requirements for affected stationary sources. IMPACTS: A greater number of DOD air emission sources will be permitted. Preparation of detailed permit applications will be required , including Compliance Pla ns for some noncompliant sources. These plans will accompany each permit application . Failure to comply with any aspect of the Compliance Plan or permit can be grounds for enforcement action. DOD installations must pay annual permit fees that are proportional to the level of air pollutants emitted. TITLE VII-ENFORCEMENT REQUIREMENTS: Title VII describes civil and criminal penalties which may be imposed for violation of new and existing air pollution control requirements. This Title almost completely replaces existing provisions of the Clean Air Act Amendments of 1977. New enforcement actions include higher maximum fines and terms of imprisonment. Some violations which were previously misdemeanors are now felonies, with liability targeted at senior management as well as operators. IMPACTS: Failure to comply with either administrative or substantive air quality requirements may be costly. Authorities may write "traffic tickets" of up to $5,000 per violati on during a routine inspection. Administrative violations, such as inaccurate or out-of-date permit data are also grounds for enforcement action. Enforcement efforts are specifically directed at management to compel regulated entities to plan ahead and allocate appropriate resources. Lack of "hands-on" involvement with a violation is not a defense for those responsible for compliance. Urban Hydrocarbon Emissions : Motor Vehicles Contribute Nearly Half Carbon Monoxide : Motor Vehicles Contribute Most Small "Area" Large PointSources : 13.5% Sources : 2 .5% Source: Office of Air and Radiation, EPA Projected Urban Air Quality Benefits Number of cities not meeting clean air standards Ozone Carbon Monoxide 1990 1995 2000 2010 Source: Office of Air and Radiation, EPA Additional significant, but less pervasive impacts will result from Titles II (Mobile Sources) and VI (Ozone Protection). TITLE II-MOBILE SOURCES REQUIREMENTS: Title II deals mostly with emissions control for motor vehicles in the form of tailpipe standards, use of clean fuels, and mandatory acquisition of clean-fuel vehicles. These requ irements compel automobile manufacturers to improve design standards to limit carbon monoxide, hydrocarbon, and NOx emissions. Manufacturers must also investigate feasibility of onboard canisters to control refueling emissions. Reformulated and oxygenated gasolines will be required in cities with worst ozone and carbon monoxide nonattainment. IMPACTS: DOD installations in affected nonattainment areas must begin to procure clean-fuel vehicles as of the 1998 model year. These vehicles must use clean alternative fuels when operating in affected areas. Clean alternative fuels include methanol, ethanol, reformulated gasoline, natural gas, liquified pet roleum gas, and electricity. Non-tactical fleet vehicles used in nonattainment areas must be included in Inspection and Maintenance (I&M) programs. Such programs generally have an annual inspection requirement which can be enforced through denial of vehicle registrations. Installations may also be required to implement a program to verify I&M participation for employees' privately owned vehicles driven on the base. TITLE VI-STRATOSPHERIC OZONE PROTECTION REQUIREMENTS: Title VI restricts production and use of chlorofluorocarbons (CFC) , halons, and other halogenated solvents which when released to the atmosphere contribute to the decomposition of stratospheric ozone. Title VI requirements closely follow control strategies recommended in June 1990 at the 2nd Meeting of Parties to the Montreal Protocol. IMPACTS: Consumption bans most important to DOD installations will be carbon tetrachloride and methyl chloroform which are used for metal parts degreasing, and CFC-113 which is used for precision cleaning of electronic devices and circuit boards. Substitute products must meet end-use specifications and EPA stratospheric ozone preservation criteria. Consumption bans on motor vehicle/ appliance refrigerants (CFC-12, HCFC-22) and fire suppressants (halons) are also important, but potentially less problematic , since acceptable commercial substitutes should be developed for this market. Alternatives for shipboard A/C and refrigeration plants and halon systems are currently being tested and evaluated by the Navy. The Navy has established a CFC/Halon Information Clearinghouse (CHIC) which can provide technical information regarding environmentally acceptable substitutes and available conservation (recovery/recycling) equipment. The Navy point of contact is Mr. Ant hony Nickens NAVSEA, Code 56Y1 c, (703) 602-5585, DSN 332-5585. U.S. Areas Where Precipitation is Below pH 5 Shaded areas indicate states having emissions of 1 ,000 kilotonnes of S02 and greater. Contours connect points of equal precipitation pH . How "Acid" is Acid Rain? "Pure" Distilled Lemon juice Vinegar rain (5 .6) water Baking soda 0 1 2 3 4 5 6 7 8 10 11 12 13 14 The pH scale ranges from 0 to 14. A value of 7.0 is neutral. Readings below 7.0 are acidic; readings above 7.0 are alkaline . The more pH decreases below 7.0, the more acidity increases. Because the pH scale is logarithmic, there is tenfold difference between one number and the next one to it. Therefore , a drop in pH from 6.0 to 5.0 represents a tenfold increase in acidity, while a drop from 6 .0 to 4.0 represents a hundredfold increase . All rain is slightly acidic. Only rain with a pH below 5.6 is considered " acid rain ." Source: Meeting the Environmental Challenge: EPA 's Review of Progress and New Directions in Environmental Protection (Dec . 1990) . TITLES IV-ACID RAIN AND VIII -MISCELLANEOUS REQUIREMENTS: These Titles have limited or no impact on DOD activities. However, acid rain is a major environmental issue in the United States and Canada, as well as several other regions around the world. Acidification of lakes, destruction of forest, and increased weathering of exposed materials are some of the effects of this pollutant. The cause of acid rain is believed to be sulfur dioxide emissions from burning fossil fuels and emissions of NOx from vehicles . The primary targets of this legislation are the very large electric utility companies which are typically the major sources of precursor elements that form acid rain. IMPACT: The only expected impact to DOD installations is a gradual increase in electricity costs over the next two decades. State regulatory agencies have the major role in the management of the air quality program. Facets of state air pollution management programs include development of State Implementation Plans (SIPs), permitting of existing stationary sources, development of regulations for air taxies emissions, and vehicle I&M programs that apply to vehicles, including Federally-owned vehicles. Since state regulations applicable to installation activities can frequently be more detailed and encompassing than Federal regulations , it is important that your installation environmental staff be fully knowledgeable of state air quality and emissions regulations . Roughly halfofthe acid rain in Canada results from pollution in the United States Utilities are the Primary Source of Sulfur Dioxide Emissions Processes : 16.4% Nonutility Fuel Combustion from Stationary Sources : 13.5% Source: Office of Air and Rad1at1on. EPA Objectives... • Identify, inventory and monitor air pollutant emissions and ambient air quality; • Reduce pollutants to regulatory levels to protect health and reduce permit costs; • Procure control equipment that meets regulatory standards; and • Ensure design and operation of military equ ipment are in accordance with regulations. Commanders should insure their environmental staff... • Identify, monitor, and maintain an up-to-date inventory of emission sources; • Obtain permits and provide reports for emission sources as required by regulations; • Participate in the air pollution regulatory development process; • Maintain programs to train air emissions management personnel; • Conduct motor vehicle I&M to ensure regulatory compliance; and • Notify appropriate higher headquarters immediately whenever a notice of violation (NOV) is received. • Plan, program and budget for appropriate funding and personnel to comply with CAAA requirements. Commander's Checklist Air Quality Regional Concerns D What is the attainment status of the region we are located in? What is the probability of restrictions on air emissions limiting our ability to accommodate new missions, force structure changes, or changes in operations? D Do we have a current air pollution emission inventory? Has it been provided to the regulatory agency? What percentage of the regional emissions do we account for? D Are we required to have an air pollution episode plan? Is it current? How many times have we had to implement it in the last five years? D Are we required to coordinate fire fighter training, controlled burning or any other activities with the local air pollution control agency? D Do we have a program to encourage car and van pooling? Stationary Sources D How many permitted sources do we have? Have we received any Notices of Violation or other enforcement actions? D Do we have a program for periodic inspection of air emission sources to assure that they are properly operated and maintained? What are the emission limits and testing requirements on our: D Boilers and other fuel burning systems? D Medical and classified wastes incinerators? D Maintenance and other industrial shops? Do we have the required emissions controls on our: D Fuel storage tanks? D Solvent degreasers? D Painting operations? Personnel D Are there any requ irements for licensing or certification of operators of air emissions sources? If yes , what sources? Do our personnel have the required certification? D Do we have a program for training operating personnel? Motor Vehicles D Do we have a program for emissions testing of motor vehicles? Does our program meet state or local government requirements? D Are our gasoline tank trucks tested for VOC emissions annually? Where Do I Go for Help? Listed below are points of contact and other sources of information on Air Pollution Management. It is important to be aware of EPA, state regulatory agencies, and local sources of information which may be helpful to personnel at individual installations. U.S. ARMY U.S.Army Environmental Office (AEO) Air Policy Office (703) 696-8078 DSN 226-8081 U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) U.S. Army Engineering and Housing Support Center (USAEHSC) Environmental Compliance Division (301) 671-2427 DSN 584-2427 U.S. Army Environmental Hygiene Agency (AEHA) Air Pollution Engineering Division Air Pollution Source Management (301) 671-3500 DSN 584-3500 Ambient Air Quality Management (301) 671-3954 DSN 584-3954 Mechanical and Energy Branch (703) 704-1544 DSN 654-1544 U.S. NAVY Chief of Naval Operations Director, Environmental Protection, Safety and Occupational Health Division, OP-45 (703) 602-2570 Commander, Naval Facilities Engineering Command (Code 18) (703) 325-8531 Commanding Officer Naval Energy and Environmental Support Activity (NEESA) (805) 982-4838 DSN 551-4838 Commanding Officer Naval Civil Engineering Laboratory (NCEL) Energy and Environmental Protection Dept. (805) 982-1355 DSN 551-1355 U.S. Marine Corps Headquarters, U.S. Marine Corps Land Use and Military Construction Branch (Code LFL) (703) 696-2138 DSN 226-2138 U.S. AIR FORC-E U.S. Air Force Installations should call their respective MAJCOM Environmental Managers or SJA. U.S. Army Commander's Guide to Environmental Management, Air Pollution Abatement, pg 53, July 1991 edition. U.S. Navy Commanding Officer's Guide to Environmental Compliance , Air Pollution Prevention, pg 54, January 1991 edition. U.S. Air Force Commander's Guide to Environmental Quality, pg 63, May 1990 edition. USATHAMA Report, "An Updated Assessment of Potential Cost Impacts of the Clean Air Act Amendments of 1990 on U.S. Army Facilities (CONUS)," December 1990. USAEHA Report, "Summary of the Clean Air Act Amendments of 1990," Titles I, II , Ill, V, VI, and VII , 4 April 1991 . NEESA Report , No . 2-171, "Clean Air Act Amendments of 1990 Impact on the Navy," May 1991 . AR 200-1 , "Environmental Protection and Enhancement," Chapter 4, April1990. AR 40-5, "Preventive Medicine," Chapter 11, August 1986. OPNAVINST 5090.1 A, "Environmental and Natural Resources Program Manual," Chapter 6. The Clean Air Act regulations are presented in Title 40 CFR Parts 50 through 87. EPA JOURNAL , Volume 17, No.1, Jan/Feb 1991, "The New Clean Air Act: What It Means to You."