11_2_2022_-_CCSFS_-_Air_Assessment_Report_0002.pdf

AIR QUALITY REGULATIONS, GUIDANCE, POLICY REVIEW

Prepared for:

Space Launch Delta 45

45 CES/CEIE

Patrick SFB Florida 32925-3343

Prepared by:

September 2022

This Page Intentionally Left Blank i Air Quality Regulations Review

Table of Contents

Table of Contents ............................................................................................................................. i Acronyms ....................................................................................................................................... iii

1.0 Introduction

2.0 USEPA Rule Review

2.1 Rule 40 CFR 60, Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

2.2 Rule 40 CFR 60 Subpart JJJJ Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

2.3 Rule 40 CFR 63 Subpart CCCCCC National Emission Standards Hazardous Air Pollutants for Gasoline Dispensing Facilities

2.4 Rule 40 CFR 63 Subpart HHHHHH National Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources

2.5 Rule 40 CFR 63 Subpart JJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers Area Sources

2.6 Rule 40 CFR 63 Subpart ZZZZ, NESHAP for IC Engines National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

2.7 Rule 40 CFR 68, CAA, Section 112(r) Risk Management Program

2.8 Rule 40 CFR 82.157 Refrigeration Appliance Maintenance and Leak Repair

2.9 Rule 40 CFR 51.166 New Source Review (NSR) Permitting

3.0 FDEP Rule Review

3.1 Rule 62-4.160(6), Florida Administrative Code (F.A.C.)

3.2 Rule 62-210.300, F.A.C

3.3 Rule 62-210.310, F.A.C

3.4 Rule 62-296, F.A.C

4.0 Air Force Rule Review

4.1 Air Force Manual, AFMAN 32-7002

4.2 Air Force Manual, AFMAN 32-1068

5.0 Point Of Contact

ii Air Quality Regulations Review iii Air Quality Regulations Review

Acronyms

AFI Air Force Instruction AFMAN Air Force Manual APIMS Air Program Information Management System BSC Base Support Contractor Btu British Thermal Unit CAA Clean Air Act (the 1990 Amendment) CCSFS Cape Canaveral Space Force Station CFR Code of Federal Regulation CI Compression Ignition CPMS Continuous Parameter Monitory System DCA Department of Community Affairs DOE Department of Energy e-CFR Electronic Code of Federal Regulations F.A.C. Florida Administrative Code FDEP Florida Department of Environmental Protection HAP Hazardous Air Pollutants HP Horse Power JDMTA Jonathan Dickinson Missile Tracking Annex KW Kilo Watt MTA Malabar Transmitter Annex NAAQS National Ambient Air Quality Standard NESHAP National Emission Standards for Hazardous Air Pollutant NRO National Reconnaissance Office NSPS New Sources Performance Standards NSR New Source Review RICE Reciprocating Internal Combustion Engines RMP Risk Management Plan PAL Plantwide Applicability Limit PWS Performance Work Statement RACT Reasonably Available Control Technology SGP South Generator Plant SI Spark Ignition SIP State Implementation Plans SLD 45 Space Launch Delta 45 USEPA United States Environmental Protection Agency VOC Volatile Organic Compounds iv Air Quality Regulations Review

1.0 Introduction

Pursuant to the Patrick F2F Contract Performance Statement of Work (PWS) 3.4.3.4 (CDRL A015), CTI-TPMC Environmental Services completed review of applicable United States Environmental Protection Agency (USEPA) and the Florida Department of Environmental Protection (FDEP) Air Quality Rules and Regulations for the period from July 2022 through September 2022. Current Air Force Manuals (AFMAN) on air quality were also reviewed.

The effort involved an online review of applicable Clean Air Act (CAA), the USEPA using the electronic Code of Federal Regulations (e-CFR) website located at “ecfr.gov/cgi-bin/ECFR?Page=browse”, FDEP air quality regulations using the FDEP website “https://www.flrules.org/” and Air Force Guidance/Policies published on the Department of Defense website https://www.e-publishing.af.mil/Product-Index/.

The applicable USEPA regulations, i.e., Standards for Stationary Internal Combustion Engines and National Emission Standards for Hazardous Air Pollutants (NESHAP), FDEP regulations Florida Administrative Code (F.A.C.), Air Force Manuals (AFMAN) and guidance documents were reviewed and are presented in Table 1-1.

Table 1-1: Possible Applicable Regulations/Guidance Documents

Rule Number Rule Title Applicable Last Ammended

USEPA

40 CFR 60 Subpart

IIII

Standards of Performance for Stationary Compression Ignition (CI) Internal Combustion Engines

Yes – CCSFS Yes – JDMTA

No - MTA

8/10/2022

40 CFR 60 Subpart

JJJJ

Standards of Performance for Stationary Spark Ignition (SI) Internal Combustion Engines

No – CCSFS No – JDMTA

No – MTA

7/29/2021

40 CFR 63 Subpart

CCCCCC

National Emission Standards for Hazardous Air Pollutants for Gasoline Dispensing Facilities.

Yes – CCSFS No – JDMTA

No – MTA

1/18/2021

40 CFR 63 Subpart

HHHHHH

National Emission Standards for Hazardous Air Pollutants:

Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources

No – CCSFS No- JDMTA No - MTA

1/18/2021

40 CFR 63 Subpart

JJJJJJ

National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers.

No – CCSFS No – JDMTA

No - MTA

7/2/2018

40 CFR 63 Subpart

ZZZZ

National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

(RICE)

Yes – CCSFS No – JDMTA Yes - MTA

1/20/2021

CAA, Section 112(r) Risk Management Plan (RMP) for Chemical Accident Prevention

No – CCSFS No – JDMTA

No - MTA

4/2020

40 CFR 82.157 Refrigeration Appliance Maintenance and Leak Repair Yes – CCSFS Yes – JDMTA

Yes - MTA

4/10/2020

40 CFR 51.166 New Source Review (NSR) Permitting Yes – CCSFS Yes – JDMTA

Yes - MTA

8/18/2021

FDEP

62-210, F.A.C. Permit Requirement for Stationary Air Emission Sources Yes – CCSFS No – JDMTA

No - MTA

3/27/2022

Rule Number Rule Title Applicable Last Ammended

FDEP

62-210.300(a), F.A.C. Categorical/Conditional Exemptions for Air Emission

Sources Yes – CCSFS Yes – JDMTA

Yes - MTA

5/16/2021

62-210.300(b), F.A.C. Generic Exemption and Temporary for Air Emission Sources

Yes – CCSFS Yes – JDMTA

Yes - MTA

5/16/2021

62-4.160(6), F.A.C Proper Operation and Maintenance of Air Emission Unit (General Conditions)

Yes – CCSFS No – JDMTA

No - MTA

6/16/2021

62-296.320(1), F.A.C Open Volatile Organic Compounds (VOC) Container Rule Yes – CCSFS Yes – JDMTA

Yes - MTA

11/5/2020

62-210.310, F.A.C. Air General Permit Yes – CCSFS No – JDMTA

No - MTA

3/27/2022

62-213, F.A.C. Title V Air Operation Permit (Major Sources of Air Pollution)

No – CCSFS No – JDMTA

No - MTA

4/8/2021

Air Force AFMAN 32-7002 Environmental Compliance and Pollution Prevention Yes – CCSFS

Yes – JDMTA Yes – MTA

2/4/2020

AFMAN 32-1068 Heating Systems and Unfired Pressure Vessels No – CCSFS No – JDMTA

No - MTA

6/16/20

2.0 USEPA Rule Review

Review of the regulations presented in Table 1-1 which currently may or may not apply to Space Launch Delta 45 (SLD 45) Air Quality Program operations at Cape Canaveral Space Force Station (CCSFS), Jonathan Dickinson Missile Tracking Annex (JDMTA) and Malabar Transmitter Annex (MTA) are presented below. USEPA regulation reviewed (e-CFR data) is current as of September 2022.

2.1 Rule 40 CFR 60, Subpart IIII Standards of Performance for Stationary Compression

Ignition Internal Combustion Engines

Rule sets emission standards for engine manufacturers as well as owners and operators for various engine categories.

Owners and operators engine categories for which emission limitations and operation requirements have been set are as follows:

1) Pre-2007 model year engines with displacement 10 liters per cylinder, greater than or equal to 10 liters per cylinder and less than 30 liters per cylinder.

2) 2007 model year and later engines with displacement less than 30 liters per cylinder.

Fourteen I.C. engines at CCSFS, Two I.C. engines at JDMTA and no I.C. engines at MTA are subject to the requirements of 40 CFR 60, Subpart IIII.

There is no cost impact to SLD 45 at CCSFS, JDMTA and MTA pertaining to air quality program or operations.

2.2 Rule 40 CFR 60 Subpart JJJJ Standards of Performance for Stationary Spark Ignition

Internal Combustion Engines

Rule sets emission standards for engine manufacturers as well as owners and operators for various engine categories.

Owners and operators engine categories for which emission limitations and operational requirements have set are as follows:

1) Engines with maximum power greater than or equal to 500 Horse Power (HP) that commence construction on or after July 1, 2007 (except lean burn engine with maximum power greater than or equal to 500 HP or less than 1,350 HP).

2) Lean burn engines with maximum power greater than or equal to 500 HP and less than 1,350 HP that commence construction on or after January 1, 2008.

3) Engines with maximum power less than 500 HP that commence construction on or after July 1, 2008.

4) Emergency engines with maximum power greater than 19 Kilo Watt (KW) (25 HP) that commence construction on or after January 1, 2009.

SLD 45 at CCSFS, JDMTA and MTA is not subject to this rule because they do not own or operate stationary spark ignition internal combustion engines.

There is no cost impact to SLD 45 at CCSFS, JDMTA and MTA pertaining to air quality program or operations.

2.3 Rule 40 CFR 63 Subpart CCCCCC National Emission Standards Hazardous Air

Pollutants for Gasoline Dispensing Facilities

Rule sets requirements based on monthly gasoline throughput as follows:

1) Gasoline Dispensing Facility (GDF) with monthly throughput of less than 10,000 gallons.

2) Gasoline Dispensing Facility (GDF) with monthly throughput of 10,000 gallons or more.

3) Gasoline Dispensing Facility (GDF) with monthly throughput of more than 100,000 gallons.

SLD 45 owns a gasoline dispensing facility at CCSFS and it is subject to the requirements of 40 CFR 63, Subpart CCCCCC based on:

1) SLD 45 dispensing records (throughput), over more than five years, SLD 45 dispensing facility at CCSFS has a consistent throughput of less than 10,000 gallons monthly.

2) The facility was exempted from permitting by FDEP during initial construction.

LB&B is the contractor who operates the gasoline dispensing facility for SLD 45 at CCSFS.

Monthly throughputs are entered and managed in the Air Program Information Management System (APIMS).

SLD 45 at JDMTA and MTA does not own nor operate a gasoline dispensing facility; therefore, this rule does not apply to these locations. There is no cost impact to SLD 45 at JDMTA and MTA pertaining to air quality program or operations.

At this time, there is no cost impact to the SLD 45 at CCSFS air quality program or operations.

However, you must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Vapor controls and system testing will be required when throughputs exceed 10,000 gallons on a monthly basis.

2.4 Rule 40 CFR 63 Subpart HHHHHH National Emission Standards for Hazardous Air

Pollutants: Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources

Rule sets requirements for surface coating or paint stripping performed on site in order to reduce air emissions from spray finishing and refinishing facilities.

1) Paint stripping operations in paint booths that involve the use of chemical strippers that contain methylene chloride.

2) Autobody refinishing operations.

3) Spray application of coatings containing compounds of cadmium, chromium, lead, manganese and nickel.

This rule does not apply to SLD 45 activities at CCSFS, JDMTA and MTA. There is no cost impact to SLD 45 at CCSFS, JDMTA and MTA pertaining to air quality program or operations.

2.5 Rule 40 CFR 63 Subpart JJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial and Institutional Boilers Area Sources

Rule sets requirements for diesel-fired boilers at area source. Gas-fired boilers are exempt from this rule.

The National Reconnaissance Office (NRO) owns and operates two diesel-fired boilers (hot water heaters) located at the Tech Support Facility 34705. The hot water heaters are less than 120 U.S. gallons flood water capacity and less than 1.6 million British Thermal Unit (Btu) per hour heat input capacity and therefore exempt from the requirements of this rule pursuant to §63.11195(f) and §63.11237 (Hot water heater definition).

The Department of Energy (DOE) updated the water heater rule for the first time in twenty years.

This is for commercial buildings in order to purchase new energy efficient water heaters that will save businesses millions of dollars in operating costs and eliminate inefficient natural gas consuming water heaters. In return, the amount of greenhouse gas emissions (carbon) will be reduced significantly.

This rule does not apply to SLD 45 located at JDMTA and MTA because they do not own or operate any boilers at these two locations. There is no cost impact to the SLD 45 at CCSFS, JDMTA and MTA air quality program or operations.

2.6 Rule 40 CFR 63 Subpart ZZZZ, NESHAP for IC Engines

National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

Rule sets standards for owners and operators of stationary Reciprocating Internal Combustion Engines (RICE) at major or area source of hazardous air pollutant (HAP) emissions, except if the stationary RICE is being tested at a stationary test cell/stand.

All stationary RICE at CCSFS, JDMTA and MTA operate on emergency basis except the five South Generator Plant (SGP) engines that operate on demand response agreement with the Florida Power & Light. The emergency units are subject to maintenance requirements of Table 2d, Item 4 of the RICE NESHAP. The SGP engines are defined non-emergency, non-black start and therefore subject to emission limitation requirements of Table 2d, Item 3 of the RICE

NESHAP.

Stationary I.C. Engines and Generators (emergency and non-emergency) operate in full compliance with USEPA and FDEP requirements. The five non-emergency engines located at the SGP contain oxidation catalysts for the exhaust system and are being monitored by the use of Continuous Parameter Monitoring System (CPMS) units.

If Pump Station 7 (PS7) changes from emergency to non-emergency engines, recommend the following scenarios:

1. Converting the deluge pump engines to electric

2. Installing catalytic converters and monitoring each engine with CPMS units

3. Turning PS7 over to commercial entities

There is a cost impact to the SLD 45 at CCSFS air quality program and operations but not at JDMTA or MTA.

2.7 Rule 40 CFR 68, CAA, Section 112(r) Risk Management Program

Rule is for Chemical Accidental Release Prevention. The rule requires companies that manufacture, process, store or handle regulated substances in amounts greater than threshold quantities prepare a worst-case scenario Risk Management Plan (RMP) analysis for accidental release prevention. Decisions relating to the activities are based on the USEPA List of Regulated Flammable Substances and List of Regulated Toxic Substances and their corresponding threshold quantities. This rule does not currently apply to SLD 45 at CCSFS, JDMTA and MTA. SLD 45 at CCSFS, JDMTA and MTA does not store any RMP listed chemicals in quantities that will trigger RMP requirements. F2F monitors thresholds of RMP chemicals annually by running reports from EESOH-MIS and APIMS.

There is no cost impact to the SLD 45 at CCSFS, JDMTA and MTA air quality program or operations.

2.8 Rule 40 CFR 82.157 Refrigeration Appliance Maintenance and Leak Repair

Rule is for maintenance and leak repair of comfort cooling appliances. A refrigeration appliance containing 50 pounds or more of any class I or class II refrigerant or blend containing a class I or class II refrigerant that leak 125 percent or more of the full charge in a calendar year (a chronically leaking appliance) must submit a report to the EPA by March 1 of the subsequent year and describe efforts to identify the leak and repair the appliance, 40 CFR 82.157(j). This rule was revised and no longer apply to appliances containing solely substitute refrigerants.

The purpose and applicability of the rule was reviewed against current SLD 45 refrigerant management at CCSFS, JDMTA and MTA. F2F Air Program Manager periodically runs reports out of APIMS refrigerant module to identify any chronic refrigerant leaks from equipment located at CCSFS, JDMTA and MTA. Due to the age and the corrosion factor of the equipment, there is always a potential risk for refrigerant leaks. There has been a few chronic refrigerant leaks to HVAC systems at CCSFS that have been replaced with new equipment.

There is a cost impact to the SLD 45 at CCSFS air quality program or operations but not currently at JDMTA and MTA.

2.9 Rule 40 CFR 51.166 New Source Review (NSR) Permitting

New Source Review (NSR) program is one of the Clean Air Act (CAA) tools designed to ensure that the air quality is better than the National Ambient Air Quality Standards (NAAQS).

Three key criteria are considered to determine which permitting program applies to a proposed new or modified source:

1) Whether the source is or will be located within a nonattainment area for a National Ambient Air Quality Standard (NAAQS).

2) Whether the air emissions will cause the source to be considered a major Stationary Source (i.e., exceeds one or more major source thresholds).

3) Whether significant amounts of specific air pollutants will be emitted (i.e., exceeds significant emission rate thresholds).

Construction of any new major stationary source, as defined in 62-210 (155)(a), F.A.C., or any major project at an existing major source in an attainment area and/or major modification to an existing major source will trigger a New Source Review (NSR) process. NSR is a procedure for calculating (before beginning actual construction or modification) whether a significant emissions increase will occur. Significant emission rate number for any air pollutant is increase over Plantwide Applicability Limit (PAL) for that air pollutant. PAL is emission limitation expressed in tons per year for a pollutant at a major source.

Significant Emissions Rate does not apply to SLD 45 at CCSFS, JDMTA and MTA air program for the following reasons:

1) SLD 45 at CCSFS, JDMTA and MTA are not a major source.

2) There are new facilities being constructed at CCSFS but no new major stationary sources and/or major modification to existing major sources, as defined in the rule, is anticipated at this time at CCSFS, JDMTA and MTA.

3) Calculated net emissions increase for construction of any minor or modification of any existing minor source at CCSFS, JDMTA and MTA is not likely to make a major source of air pollution.

Planning phases for new generators at CCSFS MRL Building #54915, MOC Building #81900 and the Integrated Capabilities Office being built next to the Skid-Strip on Flight Control Road will not change the status of minor air pollutant sources nor the air permit status. A new generator at MTA is in the design review stage.

There is no cost impact to the SLD 45 at CCSFS, JDMTA and MTA air quality program or operations.

3.0 FDEP Rule Review

3.1 Rule 62-4.160(6), Florida Administrative Code (F.A.C.)

Rule establishes uniform general conditions for all permits. The conditions include terms, conditions, requirements, limitations, and restrictions. Rule 62-4.160(6), F.A.C. specifically requires operators to exercise proper emission unit maintenance and proper house keeping. The purpose and applicability of the rule was reviewed.

There is no cost impact to the SLD 45 at CCSFS, JDMTA and MTA air quality program or operations.

3.2 Rule 62-210.300, F.A.C.

Rule covers Stationary Air Emission Sources and establishes permit requirements for non-Title V Air emission sources. Specifically, Rule 62-210.300(1), F.A.C. specifies requirements for construction permits for new air emission sources. Rule 62.210.300(3)(a) list sources and operations which are either categorically or conditionally exempt from permitting and permit requirements. Rule 62-210.300(3)(b) lists generic and temporarily exempt sources. The rule also specifies the conditions under which the sources are deemed exempt. The rule was reviewed to ensure that the SLD 45 emission units and operations at CCSFS, JDMTA and MTA are performed in manners that do not exceed exemption thresholds. F2F Air Program Manager on a monthly basis runs compliance assessments reports from APIMS to make sure that emission thresholds are not exceeded.

In summary, the Significant Emissions Rate, as defined in 62-210.300(236), F.A.C., does not apply to SLD 45 operations at CCSFS, JDMTA and MTA. In addition, the NEPA review process will prevent the construction of any new major source of emissions without proper planning.

There is no cost impact to the SLD 45 at CCSFS, JDMTA and MTA air quality program or operations.

3.3 Rule 62-210.310, F.A.C.

This rule does not pertain to SLD 45 at JDMTA and MTA because they do not operate under any air permits; therefore, there is no cost impact to the SLD 45 at JDMTA and MTA.

The rule establishes Air General Permit requirements for select operations. Its purpose is to streamline the permitting process and was promulgated on 10 January 2007. The current version (27 March 2022) of the Air General Permit Rule was reviewed for changes in general and specific requirements such as:

1) Administrative corrections,

2) Use of Air General Permit,

3) Duration of use (re-registration),

4) Renewal requirements,

5) A description of and cause of noncompliance,

6) The period of noncompliance, including dates and times, and

7) Limitation on fuel use.

CCSFS operates under the Air General Permit for stationary I.C. engines.

No changes were observed and there is no cost impact to the SLD 45 at CCSFS air quality program or operations. SLD 45 Stationary I.C. Engines and Generators are operated in full compliance with USEPA (RICE NESHAP) and FDEP (Air General Permit) requirements.

3.4 Rule 62-296, F.A.C.

Rule establishs emission limiting standards and compliance requirements for stationary sources of air pollutant emissions. The rule includes emission limitations for specific categories of facilities and emissions units, and it establishes Reasonably Available Control Technology (RACT) requirements, work practice standards, including requirements for specific types of pollution control equipment. No changes were observed during this reporting period.

There is no cost impact to the SLD 45 at CCSFS, JDMTA and MTA air quality program or operations.

4.0 Air Force Rule Review

4.1 Air Force Manual, AFMAN 32-7002

AFMAN 32-7002 (4 February 2020) is the Air Force Manual for Environmental Compliance and Pollution Prevention. This document supersedes Air Force Instruction, AFI 32-7040, 4 November 2014, AFI 32-7042, 7 November 2014; AFI 32-7086, 4 February 2015, AFMAN 32-7086, 4 November 2016 and AF Form 3952. The AFMAN establishes guidance and procedures for Air Force-wide environmental compliance (air quality compliance, refrigerant management, etc.).

The AFMAN was reviewed against the SLD 45 air program operations including refrigerant management and found to be in compliance with USEPA and FDEP requirements of the Clean Air Act and Stratospheric Ozone Protection Program.

The Base Support Contractor (BSC) who operates and performs maintenance on most of the facilities and equipment located on CCSFS has a large cost to maintain SLD 45s infrastructure.

It takes a great deal of manpower to stay in compliance with USEPA and FDEP. If the BSC could afford to employee more manpower in the generator and refrigerant shops, better documentation entry into APIMS could be maintained and accountability be more accurate.

4.2 Air Force Manual, AFMAN 32-1068

AFMAN 32-1068 (16 June 2020) is the Air Force Manual for Heating Systems and Unfired Pressure Vessels. This document supersedes AFI 32-1068, 8 February 2017. The AFMAN establishes guidance and procedures on installation, operation, maintenance and inspection of heating systems and unfired pressure vessels throughout the Air Force.

The AFMAN was reviewed and does not pertain to SLD 45 at CCSFS, JDMTA and MTA.

5.0 Point Of Contact

Patrick F2F conducted the air quality regulation review and is responsible for the information contained therein with respect to accuracy and completeness. Questions on the accuracy and completeness of the air quality regulation review are to be directed to Patrick F2F. The point of contact is Frances A. Dixon at telephone number (321) 536-7098 or email at frances.dixon.1.ctr@spaceforce.mil.

5.0 Point Of Contact