Air Emissions Training

Air Emissions Assessor Training: 

Air Emissions Assessor Training Before You Begin Training Objective Legal Requirements Assessment Schedule Assessment Scenarios www.ecamp-online.net Introduction Next

User Tips – Navigating: 

User Tips – Navigating “Next” advances to the next slide “Home” returns to the first slide

Before You Begin: 

Before You Begin First complete the General Assessor Training module Download these slides to your computer Print a copy of the handout, if you might find it useful while navigating the presentation

Using the Compliance Guide: 

Using the Compliance Guide Download the Air Emissions Compliance Assessment Guide from www.ecamp-online.net Click Air Emissions under Protocol Resource Pages Select Compliance Guide This guide is the “textbook” to accompany the slides

Printing Checklists: 

Printing Checklists Print the relevant checklist for your assessment area from www.ecamp-online.net Click View/Print Checklists under Misc on the Home Page or Click Assessment Preparation from the menu on the left after you have logged in

Assessor Training Objective: 

Assessor Training Objective Next Home

Training Objective: 

Training Objective Primary purpose – prepare personnel assigned to highly enforceable protocols on external compliance assessments Secondary purpose – prepare personnel to participate on internal compliance assessments

Assessment Emphasis: 

Assessment Emphasis External compliance assessments emphasize state and federal requirements Links to state requirements will be available on the Assessment Preparation web page on www.ecamp-online.net Your Major Command (MAJCOM) Environmental, Safety, and Occupational Health Compliance Assessment and Management Program representative will give you information to access this site before the assessment

Slide9: 

Next Home

Topics in This Module: 

Topics in This Module Air Pollutants Legal Requirements Assessor Assignments Protocol Elements Schedule Priorities Approach Scenarios Summary

Air Pollutants: 

Air Pollutants Federal Air Pollutants Nitrogen oxides (NOx), particulate matter, particulate matter less than 10 microns in diameter, carbon monoxide, sulfur dioxide, lead, and ozone [volatile organic compounds (VOCs) are controlled to meet ozone standard] Hazardous air pollutants [188 pollutants or groups of pollutants listed in the Clean Air Act (CAA)] States may regulate additional toxic air pollutants

Legal Requirements: 

Legal Requirements Federal CAA and state law are basis for regulations The Environmental Protection Agency (EPA) mandates minimum requirements under federal law EPA establishes and delegates new source performance standards and maximum achievable control technology emission standards

Legal Requirements (cont.): 

Legal Requirements (cont.) States set rules to meet both EPA-mandated requirements and state requirements EPA approves state rules EPA directly regulates automobiles (except in California) and chlorofluorocarbons

Assessor Assignments: 

Assessor Assignments Assessors are assigned to review protocol elements based on their interest and experience They must take responsibility for the completeness and consistency of the assessment of their assigned areas They must coordinate with one another at the end of each day to ensure that all elements of air emissions management have been reviewed

Protocol Elements: 

Protocol Elements Emissions inventory Lists sources on-base and activity level May be a compliance item, in addition to being an Air Force requirement, if required by state rule Permits (both construction and operating) Permit applications

Protocol Elements (cont.): 

Protocol Elements (cont.) Common sense All Air Force bases have similar sources Review sources on own base Focus review on high priority areas Highest priority is any outstanding notices of violation Any source type listed by the Regional Environmental Office Sources listed on permits and/or subject to specific rules

Protocol Elements (cont.): 

Protocol Elements (cont.) State Rules Determine whether state rules require annual/monthly reports Determine what annual/monthly reports state rules require Compare source sizes and types covered in state rules to those listed in the base emissions inventory

Training Focus: 

Training Focus This training focuses on permits, recordkeeping, and sources of air emissions.

Assessment Schedule: 

Assessment Schedule Specific assessment schedule varies by MAJCOM Before assessment begins Coordinate with your partner on splitting assessment responsibilities Assign sites to visit (examples are shown on the following slides)

Assessment Day 1: 

Assessment Day 1 Interview Environmental Flight personnel responsible for the air emissions management program Examine base data, including air permits, records, and reports Review Army and Air Force Exchange Service (AAFES) service station operations

Assessment Day 2: 

Assessment Day 2 Maintenance Group/Operations Group flightline operations

Assessment Day 3: 

Assessment Day 3 Vehicle Maintenance Services Squadron Heat Plant Tenants

Assessment Day 4: 

Assessment Day 4 Civil Engineer (CE) shops

Assessment Priorities: 

Assessment Priorities Enforceable federal and state legal requirements Not keeping these priorities in mind is the most common mistake external compliance assessors make Remember Your state rules only apply in your state Your procedures only apply to your base

Assessment Approach: 

Assessment Approach Review state rules and definitions Review permits Determine potentially affected sources Visit sources of air emissions on-base

State Rule Review: 

State Rule Review Determine air quality levels in area Attainment or nonattainment Review permit requirements Recordkeeping requirements Source emission limits Review potentially applicable rules

State Rule Review (cont.): 

State Rule Review (cont.) Note rules apply based on attainment status Nonattainment rules are more stringent than attainment rules Note whether area’s status is nonattainment; the most common nonattainment pollutant is ozone Requires controls on VOC and NOx emission sources

State Definitions : 

State Definitions Definitions vary from state to state Common areas of difference Major source definition [varies from 25 tons per year (tpy) in New Jersey to 100 tpy in North Dakota] Rule coverage differences (examples) Miscellaneous metal part Most states define by standard industrial classification code, some do not Solvent cleaner Most states cover all or none Some cover by type or size

State Definitions (cont.): 

State Definitions (cont.) Base may be “major” or “synthetic minor” source Choice is function of state requirements and base choice Review definitions of “exempt” or sources always not covered and “insignificant” source or sources exempt by size

Permit Review: 

Permit Review Review planned construction projects and identify any permit requirements for new sources Permit requirements vary from state to state Determine whether a construction permit is needed for any existing source Review current operating permit for base (required for all bases)

Construction Permits: 

Construction Permits Construction permits typically needed Boilers >10 million British thermal units (MMBtu)/hour (as low as 1 MMBtu in some states) Generators – most states exempt (not all) Most paint booths Some abrasive bead blasters

Construction Permits (cont.): 

Construction Permits (cont.) Construction permits typically needed (cont.) Petroleum, oils, and lubricants tanks >40,000 gal (some smaller) Engine test cells (states may differentiate between mounted and dismounted engines) Gasoline service stations

Construction Permits (cont.): 

Construction Permits (cont.) Construction permit requirements depend on state Almost any source could require a permit All construction permits should be referenced in the base operating permit

Assessment Scenarios: 

Assessment Scenarios Assessment scenarios that follow this slide are organized around Organizations to interview Activities Interviews with individual organizations may address several air emission issues Activities are specific to the management of a specific air emission source

Assessment Scenarios (cont.): 

Assessment Scenarios (cont.) Each scenario has a slide like the one on the right to give you an opportunity to pause Draw your conclusions before proceeding to an explanation

Environmental Flight Interview: 

Environmental Flight Interview

Environmental Flight Interview: 

Environmental Flight Interview Determine who is responsible for the air emissions management program Refer to the compliance assessment guide sections on Gathering Information Activity-Specific Guidance on Assessing Compliance

Selected Records to Review: 

Selected Records to Review Air emissions inventory List of sources Operating permit List of sources List of applicable regulations Reports filed with the state Construction permits Permits Reports filed with the state

Emission Inventory : 

Emission Inventory Determine whether State rule requires an inventory All sources are included Emission factors are documented (AP-42) Activity levels are reasonable (based on common sense and own base)

Operating Permit : 

Operating Permit Determine whether All sources are included Applicable regulations appropriately identified Required reports filed Required data collected

Construction Permits: 

Construction Permits Determine whether Construction permits obtained before construction, where required Permit conditions complied with Required reports filed

What If You Discover?: 

What If You Discover? Air emissions inventory Miscalculates potential emissions from a rock crusher Includes sources, such as portable generators, that should not be included in a stationary source inventory Includes an asphalt batch plant for which no potential emissions are specified on the inventory

Do You Have A Finding?: 

Do You Have A Finding? Is inaccurate inventory a finding If yes, why? If no, why not?

Inaccurate Inventory: 

Inaccurate Inventory Air Force Instruction (AFI) 32-7040, Paragraph 2.8, and AFI 48-119, Paragraph 9.5.1.2, require installations to prepare and periodically update a comprehensive base air emissions inventory States also have requirements for submitting emission inventories for owners of stationary sources (refer to state-specific requirements in the checklist)

Inaccurate Inventory (cont.): 

Inaccurate Inventory (cont.) Refer to TEAM Guide Checklist Reference Number A.01.7 (for AFI question) and state-specific requirements, if it is a state requirement Document this finding as an inaccurate inventory Double-click on the icon to view an example of a finding against a state requirement

What If You Discover?: 

What If You Discover? A construction permit was not obtained for constructing a paint booth that is subject to construction permit requirements

Do You Have A Finding?: 

Do You Have A Finding? Is lack of an construction permit a finding If yes, why? If no, why not?

No Construction Permit : 

No Construction Permit States have established requirements for constructing sources that must meet permit or permit-by-rule requirements Review state construction permit requirements

Construction Permit Finding: 

Construction Permit Finding Refer to TEAM Guide Checklist for the state-specific requirements for construction permits Document this finding as construction permit not obtained Double-click on the icon to view an example finding

What If You Discover?: 

What If You Discover? The state operating permit requires that VOC emissions from paint booths be computed Allied Trades at Vehicle Maintenance uses a paint log to track VOC emissions The paint log does not document use of wipe solvent to prepare the vehicle for painting

Permit Requirements: 

Permit Requirements Most states have implemented operating permit programs Permit conditions specified in operating permits must be met

Permit Conditions Not Met: 

Permit Conditions Not Met Refer to TEAM Guide Checklist for the state-specific requirements for operating permits Document this finding as permit conditions not met Double-click on the icon to view an example finding

Shop Visits: 

Shop Visits General Approach Process view Concern is what materials are used and how the materials are used Materials used provide data on the possible emissions How materials are used gives data on emissions

Shop Visits (cont.): 

Shop Visits (cont.) “Look around” the shop Pause and formulate the questions you would ask

Shop Visits (cont.): 

In each shop look for sources like Solvent cleaners (parts washers) Paint guns Solvent containers Shop Visits (cont.)

Shop Visits (cont.): 

Shop Visits (cont.) Review all storage cabinets Determine what materials are used Determine how materials are used Ask how much material is used

Vehicle Maintenance: 

Vehicle Maintenance

Vehicle Maintenance Shop: 

Vehicle Maintenance Shop Refer to compliance assessment guide sections on Gathering Information Organization-Specific Guidance on Assessing Compliance

Selected Sources to Review: 

Selected Sources to Review Vehicle emission testing Testing records Solvent cleaners Types of solvent cleaners Process/operation description Freon Recovery Equipment certifications Operator certifications

Vehicle Emission Testing: 

Vehicle Emission Testing If the state requires testing vehicles, then all government vehicles must be tested AAFES, Services, Government Services Administration, and perhaps tenants can own and maintain vehicles in addition to those Vehicle Maintenance routinely maintains

What If You Discover?: 

What If You Discover? Marine Corps Reserve tenant vehicles lack the required emissions testing

Do You Have A Finding?: 

Do You Have A Finding? Is lack of emission testing a finding If yes, why? If no, why not?

No Emission Testing: 

No Emission Testing States implement testing requirements to ensure federal vehicle emissions requirements are met (refer to state-specific requirements in the checklist)

No Emission Testing (cont.): 

No Emission Testing (cont.) Refer to TEAM Guide Checklist for the state-specific requirements for emission testing of vehicles Document this finding as no emission testing of vehicles (state requirements will be used to cite the finding) Double-click on the icon to view an example finding

Solvent Cleaners: 

Solvent Cleaners If the state has solvent cleaner rules, then cleaners must comply with typical rules such as Closed lids Drainage racks Posted operating instructions Missing operating instructions is common

What If You Discover?: 

What If You Discover? Paint gun cleaners at Corrosion Control and Vehicle Maintenance paint booths and a solvent tank at Munitions have signs indicating responsible parties and type of solvent, but no instructions on use

Solvent Cleaner Rules: 

Solvent Cleaner Rules State rules require specific environmental operating instructions to be posted

Solvent Cleaner Finding: 

Solvent Cleaner Finding Refer to TEAM Guide Checklist for the state-specific requirements for solvent cleaners Document this finding as operating instructions not posted Double-click on the icon to view an example finding

Ozone-Depleting Chemicals (Freon Recovery): 

Ozone-Depleting Chemicals (Freon Recovery) Check all areas that do air conditioning work This includes CE Heating, Ventilation, and Air Conditioning; Vehicle Maintenance; Aerospace Ground Equipment; Housing Maintenance; and sometimes Avionics Determine whether technicians are certified Determine whether equipment is certified by the shop with EPA

What If You Discover?: 

What If You Discover? The housing maintenance contractor has changed The new contractor has not certified to EPA that he/she will use certified equipment for Freon recovery and will use the equipment properly

Do You Have A Finding?: 

Do You Have A Finding? Is lack of certification submittal a finding If yes, why? If no, why not?

No Certification Submittal: 

No Certification Submittal 40 Code of Federal Regulations (CFR) 82.162 requires persons maintaining, servicing, repairing, or disposing of appliances to certify to the EPA Administrator that he/she has acquired certified recovery or recycling equipment and is complying with the applicable requirements of 40 CFR 82.162

No Certification: 

No Certification Refer to TEAM Guide Checklist A.07.3.9 Document this finding as lack of submittal of certification to EPA Double-click on the icon to view an example finding

Corrosion Control: 

Corrosion Control

Corrosion Control Shop: 

Corrosion Control Shop Refer to compliance assessment guide sections on Gathering Information Organization-Specific Guidance on Assessing Compliance

Selected Sources to Review: 

Selected Sources to Review Paint booths Paint and solvent logs Paint cleaning procedures Abrasive blasting Blast media logs Equipment ventilation system and state requirements

Paint Booths: 

Paint Booths Review permit requirements (keeping a log is a frequent requirement) If a log is required, make sure ALL VOC-containing materials are covered Frequently, wipe solvent or cleanup solvent is not included since the use is very small and tracking is difficult

Paint Booths (cont.): 

Paint Booths (cont.) Review paint cleaning procedures If the state has solvent cleaning rules then Paint gun cleaners may be solvent cleaners and must follow all rules Flushing the thinner through the gun and into the air is improper cleaning

What If You Discover?: 

What If You Discover? Corrosion Control personnel clean the paint guns by flushing thinner through the gun into the air

Do You Have A Finding?: 

Do You Have A Finding? Is flushing thinner through paint gun into the air a finding If yes, why? If no, why not?

Improper Cleaning Practice: 

Improper Cleaning Practice States may have requirements for solvent cleaning to be done in closed containers meeting certain conditions (refer to state specific requirements in the checklist) In addition, disposing of solvent by flushing it into the air where it mixes with paint on the paint booth filter may constitute improper hazardous waste disposal and change the disposal requirements for the filter

Improper Cleaning Practice: 

Improper Cleaning Practice Refer to TEAM Guide Checklist for the state-specific requirements for solvent cleaning Document this finding as improper cleaning practice Double-click on the icon to view an example finding

Stack Emissions: 

Stack Emissions

Look for Excess Emissions: 

Look for Excess Emissions Clearly the smoke is too thick on the left. This is a violation anywhere. It should look like the picture on the right

Summary: 

Summary

Findings Summary : 

Findings Summary The scenarios resulted in the following types of findings Inadequate air emissions inventory Missing construction permit Operating permit conditions not met No emission testing of vehicles Operating instructions not posted on solvent cleaner Certification not submitted to EPA on Freon-recovery equipment These are the common findings during external assessments

Identifying These Findings: 

Identifying These Findings You identified these deficiencies by Reviewing shop activities for materials used and processes conducted to identify sources of air emissions Looking at activities in the shop and asking about how shop personnel do their work (unpermitted sources) Examining permits and records relative to recordkeeping requirements

Contract: 

Contract These slides were updated under Air Combat Command Contract FA4890-04-D-0005 Task Order 5005 Next Home