Attach__No__1B_-_Air_Qty_Pro__Mngt_Playbook.pdf

Air Quality Program Management Playbook Consolidated PDF

Date of Playbook Consolidation: 29 September 2014

Note: Please check the Playbook on the CE Portal for the most updated version. Updates are communicated through the “Playbook Updates” list on the right hand side of each Playbook.

Air Quality Program Management – (Plan) – Overview

Introduction to the Air Quality Program Management Playbook Introduction to the Air Quality Program

Introduction to the Air Quality Program Management Playbook

Playbook Purpose, Goals, and Scope

The purpose of the Air Quality Program Management Playbook is to provide process and informational narrative guidance to ensure compliance with the Clean Air Act (CAA), Title 40, Code of Federal Regulations (CFR), Part 98, Mandatory Reporting of Greenhouse Gases, and Air Force Instruction (AFI) 32-7040, Air Quality Compliance and Resource Management. Air Quality Program Managers and base level personnel accomplish this by upholding emissions reporting standards and inspection and maintenance (I&M) requirements for mobile and stationary sources. Geographically separated units (GSU) and overseas locations are bound by local laws and regulations and may therefore require specialized consideration; they should consult the Final Governing Standard (FGS) or Overseas Environmental Baseline Guidance Document (OEBGD) where no FGS exists.

In accordance with AFI 32-7001, Environmental Management and Program Action Directive (PAD) 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation, the Air Quality Program should meet Environmental Management System (EMS) requirements and follow the Plan, Do, Check, Act (PDCA) framework. For more information about EMS, refer to the EMS Playbook on the Civil Engineer (CE) Portal.

Following the PDCA framework, the Playbook is organized according to the table in the Playbook Organization section below.

Limitation

This Playbook does not replace, supersede, or circumvent existing Department of Defense (DoD) or Air Force policy.

Federal, state, local or outside of the continental United States (OCONUS) regulations and permit conditions take precedence over the guidance in this Playbook.

Playbook Roles

The major roles involved in the Air Quality Program Management Playbook are the Base Air Quality Program Manager, Air Force Civil Engineer Center Installation Support Team (AFCEC IST), and AFCEC Environmental Directorate (CZ).

AFCEC/CZ provides more of an oversight role, while the AFCEC IST and Base Air Quality Program Manager collaborate on day-to-day program management. The AFCEC IST also provides execution support for environmental compliance, conservation, permit research and development, and data call approval. Additionally, AFCEC serves as the center for EQ technical expertise to provide reach-back support and subject matter expertise to installations on technical issues.

Playbook Organization

The organization of the Air Quality Program Management Playbook follows the PDCA cycle in the below table:

Name of Playbook Section Alignment to EMS (Plan, Do, Check, Act) Overview Plan High Level Plan, Do, Check, Act

1.0 Plan Plan

1.1 Establish Strategic Plan Plan

1.2 Conduct Risk Management Planning Plan

1.3 Determine Type of Permit Required Plan

1.4 Create New or Modify Permit Plan

1.5 Prepare of Vehicle Inspection Maintenance Plan

1.6 Determine General Conformity and NEPA Plan

1.7 Develop ODS Management Plan Plan

2.0 Do (Implement) Do

2.1 Manage AEI Do

2.2 Train Users on Air Emissions Do

2.3 Complete and Submit Reports Do

2.4 Develop and Maintain Compliance Checklist Do

2.5 Implement and Respond to Data Calls Do

2.6 Implement Vehicle Inspection Maintenance Do

2.7 Manage ODS Do

2.8 Conduct Monitoring and Maintain Records Do

3.0 Check (Compliance) Check

3.1 Prepare of External Inspection and Internal

Audits/Assessments

Check

3.2 Perform External Inspections and Internal

Audits/Assessments

Check

4.0 Act (Management Review) Act

4.1 Evaluate Performance Measures Act

4.2 Perform Air Quality Review Act

Introduction to the Air Quality Program

About the Air Quality Program

The vision of the Air Quality Program is for all stationary and mobile sources to meet or exceed all Air Force mission requirements in full regulatory compliance. The specific objectives are to have 100% CAA compliant sources and 100% compliant CAA air pollution control permits.

Drivers of the Air Quality Program

Amongst current key drivers of the Air Quality Program are the:

• Clean Air Act

• 40 CFR 98, Mandatory Reporting of Greenhouse Gases

• AFI 32-7040, Air Quality Compliance and Resource Management

Additionally, the PAD 12-03 Implementation of Enterprise-Wide Civil Engineer Transformation dictates the following:

• 1.1 The AFCEC will manage the EQ and environmental planning function (EPF) responsibilities formerly located at MAJCOMs to include combatant command (COCOM) environmental support at United States Air Forces in Europe (USAFE) and Pacific Air Forces (PACAF)

• 2.1.3.1: AFCEC: Plans, organizes, directs and controls the Air Force EQ programs of the installations on behalf of the AF/A7C and the MAJCOMs. Provides support for environmental compliance, conservation and P2 programs

• 2.1.5.1: Installation: retains local compliance management of the installation environmental compliance, conservation, P2 programs to ensure compliance with all federal, state, and local laws and regulations.

Accountability and primary responsibility for environmental compliance will remain at the installation

• 2.1.3.2: AFCEC supports and maintains the effective implementation of the Air Force Environmental Management System (EMS) to include coordination with necessary mission support areas

• 2.1.5.2: Installation CCs will continue to chair installation-level Environmental Safety and Occupational Health (ESOH) Council and provide oversight of the installation EMS

The ISO14001, International Standard for Environmental Management Systems – Requirements with guidance for use also provides guidance on how the Air Quality Program should be established, implemented, and maintained to operate under the EMS framework.

Additional Resources

The Air Force Air Quality home page is available at https://cs1.eis.af.mil/sites/edash/Web%20Part%20Pages%20%20Program%20Pages/Environmental/Air%20Quality.as px.

https://cs1.eis.af.mil/sites/edash/Web%20Part%20Pages%20%20Program%20Pages/Environmental/Air%20Quality.aspx https://cs1.eis.af.mil/sites/edash/Web%20Part%20Pages%20%20Program%20Pages/Environmental/Air%20Quality.aspx

Air Quality Program Management – High Level

Introduction Narrative

The High Level process outlines the progression of the Air Quality Program Management Playbook sections. This Playbook follows the Environmental Management System (EMS) – Plan, Do, Check, Act (PDCA) framework.

Process 1.0 – Plan Role: N/A

This section describes the planning activities conducted under the Air Quality Program, beginning with establishing a strategic plan. Planning processes include determining permits, preparing for vehicle inspection and maintenance, performing Air Quality Environmental Impact Analysis Planning (EIPA), and developing an ozone depleting substances (ODS) management plan.

Process 2.0 – Do (Implement)

This section contains the processes that fall under the Do (Implement) phase of the Environmental Management System (EMS). In general, the processes cover management of the Air Emissions Inventory (AEI), management of ODS, training, completion and submission of reports, responding to data calls, and recordkeeping.

Process 3.0 – Check (Compliance)

This section describes the processes of preparing for and performing external inspections and internal audits/assessments to comply with the Check Phase of EMS.

Process 4.0 – Act (Management Review)

This section describes the processes of evaluating performance measures and performing management review of the Air Quality program to comply with the Act Phase of EMS.

Air Quality Program Management – (Plan, Do, Check, Act) – High Level

= Predefined Process

= Decision Point

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Shape Key

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= Phase>

= Annotation

= High Level Process

Plan

1.0

Do

(Implement)

2.0

Check

(Compliance)

3.0

Act

(Management

Review)

4.0

Air Quality Program Management – 1.0 Plan

Roles and Responsibilities

Process 1.0 Plan describes the planning activities conducted under the Air Quality Program, beginning with establishing a strategic plan.

Process 1.1 – Establish Strategic Plan

Entry from Process 3.2 Perform External Inspections and Internal Audits/Assessments.

Entry from Process 4.1 Evaluate Performance Measures.

Entry from Process 4.2 Perform Air Quality Review.

This process describes the steps involved in establishing a strategic plan for the Air Quality program using relevant regulations and guidance to outline goals to reduce the emission of air pollutants on every base. This process feeds into all other processes.

Proceed to Process 1.2 Conduct RMP.

Proceed to Process 1.3 Determine Type of Permit Required.

Proceed to Process 1.4 Create New or Modify Permit.

Proceed to Process 1.5 Prepare for Vehicle Inspection Maintenance.

Proceed to Process 1.6 Perform Air Quality EIAP (Conformity and NEPA).

Proceed to Process 1.7 Develop ODS Management Plan.

Proceed to Process 2.0 Do.

Proceed to Process 3.0 Check (Compliance).

Proceed to Process 4.0 Act (Management Review).

Process 1.2 – Conduct RMP

Entry from Process 1.1 Establish Strategic Plan.

This process describes the steps involved in conducting an RMP applicability analysis, and developing and implementing such a plan if required.

Proceed to Process 2.4 Develop and Maintain Compliance Checklist.

Proceed to Process 2.8 Conduct Monitoring and Maintain Records.

Process 1.3 – Determine Type of Permit Required

Entry from Process 2.1 Manage AEI.

This process describes the steps involved in determining the type of permit(s) required, based on changes in requirements or sources.

Proceed to Process 1.4 Create New or Modify Permit.

Proceed to Process 2.3 Complete and Submit Reports.

Process 1.4 – Create New or Modify Permit

Entry from Process 1.3 Determine Type of Permit Required.

This process describes the steps involved in ensuring that a new permit application or modification is created properly, the application is successfully submitted, and the approved permit is coordinated with the other existing permits on the base so as to maintain all operations IAW with all statutory requirements.

Proceed to Process 2.1 Manage AEI.

Proceed to Process 2.2 Train Users on Air Emissions.

Proceed to Process 2.3 Complete and Submit Reports.

Process 1.5 – Prepare for Vehicle Inspection Maintenance

Entry from Process 2.2 Train Users on Air Emissions.

Entry from Process 2.5 Implement and Respond to Data Calls.

This process describes the steps involved in preparing for vehicle inspection maintenance.

Proceed to Process 2.2 Train Users on Air Emissions.

Proceed to Process 2.4 Develop and Maintain Compliance Checklist.

Proceed to Process 2.6 Implement Vehicle Inspection Maintenance.

Process 1.6 – Perform Air Quality EIAP (Conformity and NEPA)

This process describes performing Air Quality Environmental Impact Analysis Planning (EIAP), to include compliance with conformity and National Environmental Policy Act (NEPA) requirements.

Process 1.7 – Develop ODS Management Plan

This process describes the steps involved in developing the Ozone Depleting Substances (ODS) Management Plan in order to reduce their impact to the environment.

Proceed to Process 2.1 Manage AEI.

Proceed to Process 2.3 Complete and Submit Reports.

Proceed to Process 2.7 Manage ODS.

Proceed to Process 3.2 Perform External Inspections and Internal Audits/Assessments.

Air Quality Program Management – 1.0 Plan

Establish

Strategic

Plan

1.1

Prepare for

Vehicle

Inspection

Maintenance

1.5

Perform Air

Quality EIAP

(Conformity and NEPA)

1.6

Conduct

RMP

1.2 Determine

Type of

Permit

Required

1.3

Create New or Modify

Permit

1.4

Develop ODS

Management

Plan

1.7

Manage AEI

2.1

Train Users on Air

Emissions

2.2

Develop and

Maintain

Compliance

Checklist

2.4

Implement and Respond to Data Calls

2.5 Implement

Vehicle

Inspection

Maintenance

2.6

Manage ODS

2.7

Conduct

Monitoring and Maintain

Records

2.8

Complete and Submit

Reports

2.3

1.3

2.3

Prepare for

External

Inspections and Internal

Audits/

Assessments

3.1 Perform

External

Inspections and Internal

Audits/

Assessments

3.2

3.2

3.2

1.12.4

Evaluate

Performance

Measures

4.1

Perform Air

Quality

Review

4.2

1.1

4.1

4.2

1.2

1.5

1.6

2.4 2.4 2.4

1.0 Plan

2.0 Do (Implement)

3.0 Check (Compliance)

4.0 Act (Management Review)

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Air Quality Program Management – (Plan) – 1.1 Establish Strategic Plan

The Air Force Civil Engineer Center (AFCEC) Environmental Directorate (CZ) is responsible for establishing a strategic plan for the Air Quality program using relevant regulations and guidance to outline goals to reduce the emission of air pollutants on every base. This strategic plan is known as the Air Quality Management Plan. AFCEC/CZ works with the AFCEC Installation Support Team (IST) and Base Air Quality Program Manager at each base to incorporate federal, state, and local requirements into Air Quality Management Plan for each base.

ROLES RESPONSIBILITIES

AFCEC/CZ AFCEC/CZ establishes the Air Quality Management Plan for the Air Quality program across the bases.

IST Each IST works with the corresponding Base Air Quality Program Manager to incorporate federal, state, and local requirements into the base strategic plan. The IST and Base Air Quality Program Manager also work together to develop base-level guidelines based on the plan and to track the impact of emerging regulatory requirements.

Base Air Quality

Program Manager

(See above.)The Base Air Quality Program coordinates with AFCEC/CZ and the IST to incorporate federal, state, and local requirements into the base Air Quality Management Plan.

Entry from Process 4.1 Evaluate Performance Measures.

Entry from Process 4.2 Perform Air Quality Review.

Step 1.1.1 – Research relevant regulations, guidance, emission controls and strategies and define new/emerging requirements Role: AFCEC/CZ

AFCEC/CZ reviews existing relevant federal, state, and local air quality regulations as well as existing guidance, emission controls and strategies. AFCEC/CZ also develops and reviews new federal, state/regional air quality guidelines.

Proceed to Step 1.1.2.

Step 1.1.2 – Define scope

AFCEC/CZ defines the scope of the strategic Air Quality Management Plan. This encompasses the Vision, Objectives, and Targets (VOT) as defined by the Air Force. VOTs are reviewed and defined annually. The scope/VOTs are based on the most recent review and include new and emerging requirements, as well as areas of concern based on reported violations.

Proceed to Step 1.1.3.

Step 1.1.3 – Identify challenges and impacts

AFCEC/CZ identifies the challenges and impacts of emerging regulatory requirements on the strategic Air Quality planning process.

Proceed to Step 1.1.4.

Step 1.1.4 – Establish goals and objectives/metrics

AFCEC/CZ establishes the goals and objectives to serve as metrics to evaluate the performance of the Air Quality Management Plan.

Proceed to Step 1.1.5.

Step 1.1.5 – Predict possible outcomes

AFCEC/CZ predicts possible outcomes of installation-level decisions and determines what constitutes acceptable results.

Proceed to Step 1.1.6.

Step 1.1.6 – Communicate intended goals to ISTs

AFCEC/CZ communicates the intended goals of the strategic Air Quality Management Plan to ISTs.

Proceed to Step 1.1.7.

Step 1.1.7 – Establish metrics to measure outcomes

AFCEC/CZ establishes the metrics that measure the outcomes of the strategic Air Quality planning.

Proceed to Step 1.1.8.

Step 1.1.8 – Provide federal requirements to base Role: AFCEC/CZ and IST

AFCEC/CZ and the IST provide federal requirements to the Base Air Quality Program Manager.

Proceed to Step 1.1.11.

Step 1.1.9 – Identify installation Air Quality aspects and impacts Role: Base Air Quality Program Manager

Entry from Process 4.1 Evaluate Performance Measures.

Entry from Process 4.2 Perform Air Quality Review.

The Base Air Quality Program Manager identifies installation Air Quality aspects and impacts.

Proceed to Step 1.1.10.

Step 1.1.10 – Rank Air Quality aspects and impacts Role: IST and Base Air Quality Program Manager

The IST and Base Air Quality Program Manager work together to rank Air Quality aspects and impacts.

Proceed to Step 1.1.11.

Step 1.1.11 – Provide input and incorporate federal, state, local requirements to create base-specific strategic plan

The IST and Base Air Quality Program Manager work together to provide input to the base strategic plan, including action plans based on the significance of impacts. This involves incorporating federal, state and local requirements, for example, from the state implementation plan (SIP), as well as comments from AFCEC.

Proceed to Step 1.1.12.

Step 1.1.12 – Develop new base-level guidelines

The IST and Base Air Quality Program Manager develop new base-level guidelines and incorporate these into the corresponding plans, in order to assist the bases in meeting Air Force-wide goals.

Proceed to Process 1.2 Conduct RMP.

Proceed to Process 1.3 Determine Type of Permit Required.

Proceed to Process 1.4 Create New or Modify Permit.

Proceed to Process 1.5 Prepare for Vehicle Inspection Maintenance.

Proceed to Process 1.6 Determine General Conformity and NEPA.

Proceed to Process 1.7 Develop ODS Management Plan.

Proceed to Process 2.0 Do (Implementation and Operation).

Proceed to Process 3.0 Check (Compliance).

Proceed to Process 4.0 Act (Management Review).

Air Quality Program Management – (Plan) – 1.1 Establish Strategic Plan B a s e

A ir Q u a lit y P ro g ra m

M a n a g e r

IS

T A

F C

E C

/C Z

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Communicate intended goals to

ISTs

1.1.6

Predict possible outcomes

1.1.5 Research relevant

regulations, guidance, emission controls and strategies and define new/ emerging requirements

1.1.1

Identify challenges and impacts

1.1.3

Establish goals and objectives/ metrics

1.1.4

Define scope

1.1.2

Establish metrics to measure outcomes

1.1.7

Provide federal requirements to base

1.1.8

Provide input and incorporate federal, state, local requirements to create base-specific strategic plan

1.1.11

Develop new base-level guidelines

1.1.12

Do

(Implementa-tion and

Operation)

2.0

Check

(Compliance)

3.0

Rank Air Quality aspects and impacts

1.1.10

Identify installation

Air Quality aspects and impacts

1.1.9

Perform

External

Inspections and Internal

Audits/

Assessments

3.2

Evaluate

Performance

Measures

4.1

Perform Air

Quality

Review

4.2

Act

(Management

Review)

4.0

Conduct

RMP

1.2 Determine

Type of

Permit

Required

1.3

Create New or Modify

Permit

1.4 Prepare for

Vehicle

Inspection

Maintenance

1.5 Determine

General

Conformity and NEPA

1.6

Develop ODS

Management

Plan

1.7

Perform

External

Inspections and Internal

Audits/

Assessments

3.2

Air Quality Program Management – (Plan) – 1.2 Conduct RMP

According to 40 CFR Part 68, Chemical Accident Prevention Provisions, owners or operators of stationary sources that produce, handle, process, distribute, or store more than a threshold quantity of regulated hazardous or extremely hazardous substance must develop and prepare a Risk Management Plan (RMP) and submit it to the appropriate regulator/agency (typically, Unite States Environmental Protection Agency [EPA]). States may establish thresholds that are lower than the federal minimum. Regardless, all stationary sources are subject to a “general duty” to plan for, prevent, and minimize the consequences of any accidental releases of extremely hazardous chemicals under § 112(r)(1) of the Clean Air Act (CAA).

This process describes the steps involved in conducting an RMP applicability analysis, and developing and implementing such a plan if required. The intent of the RMP is to prevent accidental releases of substances that can cause serious harm to the public and the environment from short-term exposures, and to mitigate the severity of releases that do occur.

Air Force Civil

Engineer Center

(AFCEC)/

Environmental

Directorate

(CZ)

AFCEC/CZ provides general guidance and standardized format to the Base Air Quality Program Manager and AFCEC IST for developing the RMP.

Installation Commander

The Installation Commander is responsible for reviewing and approving the RMP before it goes to the appropriate regulator/agency and signing the final version as the Responsible Official for the installation.

Installation Support Team

(IST)

The IST supports and works with the Base re-accomplished Program Manager to develop the RMP and to obtain the proper approval.

Base Air Quality

Program Manager

The Base Air Quality Program Manager conducts the RMP applicability analysis, develops the RMP, and seeks approval for the RMP from the Installation Commander as well as the proper regulators/agencies.

Regulatory Agency

The regulatory agency reviews the RMP and approves it or returns it to the base for revisions.

Step 1.2.1 – Provide general guidance and standardized RMP format

AFCEC/CZ provides general guidance regarding the RMP to the Base Air Quality Program Manager. Such guidance includes EPA guidance, CAA Section 112(r), 40 CFR 68, among other resources.

Proceed to Step 1.2.2.

Step 1.2.2 – Review general guidance and standardized RMP format

The IST and Base Air Quality Program Manager review general guidance related to the risk management program through resources such as the EPA, Section 112(r) of the CAA, 40 CFR 68, their local regulatory agency, and other resources. They review and become familiar with the standardized RMP format.

Proceed to Decision 1.2.3.

Decision 1.2.3 – Does the facility use 112(r) regulated substances?

The Base Air Quality Program Manager determines if any substances listed under Section 112(r) of the CAA are maintained on their installation in quantities exceeding the regulatory Threshold Quantity (TQ) at any “single process.”

If the facility has exceeded the TQ for any 112(r) regulated substances, in a single process, they must then develop and implement a RMP as specified 40 CFR Part 68.

Refer to the following sources for guidance:

• http://www.epa.gov/oem/docs/chem/caa112_rmp_factsheet.pdf

• http://emergencymanagement.supportportal.com/link/portal/23002/23016/ArticleFolder/599/Applicability

If ‘Yes,’ proceed to Decision 1.2.6.

If ‘No,’ proceed to Decision 1.2.4.

Decision 1.2.4 – Does the facility use extremely hazardous substances?

The Base Air Quality Program Manager determines if the facility uses extremely hazardous substances. If the facility does use extremely hazardous substances, they must refer to section 1112(r) of the CAA to determine regulatory applicability and follow appropriate protocol under the General Duty Clause.

If ‘Yes,’ proceed to Out-of-Scope Step 1.2.5 Follow 112(r) General Duty Clause.

If ‘No,’ proceed to Process 2.8 Conduct Monitoring and Maintain Records.

Out of Scope Process 1.2.5 – Follow 112(r) General Duty Clause

The base follows CAA 112(r) if the facility uses extremely hazardous materials.

Decision 1.2.6 – Are 112(r) substances used in excess of listed Threshold Quantities?

The Base Air Quality Program Manager determines the specific Threshold Quantity for all regulated substance in use at the installation and if that limit has been exceeded by any single process. The list for regulated threshold substances is located in 40 CFR Part 68, Appendix A or CAA section 112(r) Title I. The Base Air Quality Program Manager must also review applicable exemptions when determining regulatory requirements for each material or process.

The threshold quantities for toxics range from 500 to 20,000 pounds depending upon the substance while listed flammables are 10,000 pounds.

If ‘Yes,’ proceed to Step 1.2.7.

If ‘No,’ proceed to Out-of-Scope Process 1.2.5 Follow 112(r) General Duty Clause.

Step 1.2.7 – Develop/revise RMP http://www.epa.gov/oem/docs/chem/caa112_rmp_factsheet.pdf http://emergencymanagement.supportportal.com/link/portal/23002/23016/ArticleFolder/599/Applicability

The program level that the base is subject to determines the contents of the RMP. Factors that are taken into consideration include the level of risk to the public, history of related mishaps, and the level of effort necessary to prevent accidents.

Proceed to Step 1.2.8.

Step 1.2.8 – Review RMP

The IST and Base Air Quality Program Manager review the RMP, incorporating edits and changes as needed, before coordination with the Installation Commander for approval and signature.

Proceed to Decision 1.2.9.

Decision 1.2.9 – Approve?

Role: Installation Commander

The Installation Commander either approves or rejects the RMP; if approved, he will sign the plan prior to submittal to the regulatory agency. Upon being signed by the Installation Commander, the IST and Base Air Quality Program Manager will coordinate the RMP with the appropriate regulators/agencies.

If the Installation Commander does not approve the RMP, he notifies the IST and Base Air Quality Program Manager of their decision and that revisions are necessary.

If ‘Yes,’ proceed to Step 1.2.10.

If ‘No,’ proceed to Step 1.2.7.

Step 1.2.10 – Coordinate with state regulators/agencies

The Base Air Quality Program Manager, with the support of the IST, coordinates with the appropriate regulatory agencies to obtain final approval of the RMP. Typically, the state regulator/agency is the EPA.

Proceed to Decision 1.2.11.

Decision 1.2.11 – Approve?

Role: Regulator/Agency

The regulator/agency is typically the EPA. If the regulator/agency approves the RMP, then the IST and the Base Air Quality Program Manager will submit the plan to their regulatory agency (via RMP*eSubmit), implement program requirements, maintain compliance, and compile/retain all necessary documentation required. If the plan is not approved by the regulatory agency, the IST and Base Air Quality Program Manager will revise the RMP to include any additional information necessary and/or address all specific policy guidance or comments provided by the regulator.

Once revisions are complete, local installation coordination and approval must be re-accomplished including obtaining the installation commanders signature as required for resubmittal to the regulator.

If ‘Yes,’ proceed to Process 2.8 Conduct Monitoring and Maintain Records.

If ‘No,’ proceed to Step 1.2.7.

Air Quality Program Management – (Plan) – 1.2 Conduct RMP a s e

A ir Q u a lit y P ro g ra m

M a n a g e r A

F C

E C

/C Z

IS

T

In s ta lla ti o n

C m m a n d e r

R e g u la to r/

A g e n c y

Review general guidance and standardized RMP format

1.2.2

Develop/revise

RMP

1.2.7

Review RMP

1.2.8

Coordinate with state regulators/ agencies

1.2.10

Approve?

1.2.11

YesNo

Approve?

1.2.9

No

Establish

Strategic

Plan

1.1

Conduct

Monitoring and Maintain

Records

2.8

Yes

Provide general guidance and standardized RMP format

1.2.1

No

Yes

Yes

No

Yes

Are 112(r) substances used in excess of listed

Threshold

Quantities?

1.2.6

1.2.5

Follow 112(r)

General Duty

Clause

Does the facility use extremely hazardous substances?

1.2.4

Does the facility use 112(r) regulated substances?

1.2.3

Conduct

Monitoring and Maintain

Records

2.8

No

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Air Quality Program Management – (Plan) – 1.3 Determine Type of Permit Required

The Air Emissions Inventory (AEI) accounts for all Air Force owned or operated activities or assets which release contaminants to the atmosphere; these activities or assets may be required to obtain a permit(s) from a regulatory agency. The data contained within an AEI provides information on total emissions by pollutant and specific sources which is utilized as part of the permit applicability determination.

Air permits are legal documents (which include statutory requirements) that the source owner/operator must comply with.

These requirements may include, but are not necessarily limited to the following; allowable construction types, emission limits, source testing, and operational procedures. Permits typically contain conditions requiring that source be constructed to match parameters as defined within the application provided to the regulatory agency for their review prior to issuance.

The Clean Air Act (CAA) is the primary statute that defines the air pollution permitting process; authority to implement and enforce these rules is delegated down to the state level once that state has submitted a State Implementation Plan (SIP) to the Federal Environmental Protection Agency (EPA) and that plan has been approved. States may further delegate this authority to local, regional or county level offices within that state. The rules promulgated by the state and/or local/regional agencies must be no less stringent than the federal statute, but may be more stringent depending on local conditions or priorities.

Specific types of activities, equipment, or pollutants may require permits depending on their Potential to Emit (PTE) and regulations promulgated by the applicable regulatory agency. Air pollution sources may require a construction or operating permit and could potentially need to obtain both. Construction permits are issued prior to installation of new sources while operating permits are required prior to commencement of operation of regulated sources. There are multiple types of operating permits; Title V, Synthetic Minor (also sometimes known as Federally Enforceable State Operating Permits [FESOP]), Permit by Rule (PBR) and Minor Source are the most common and widely known types of permits. These permits can be issued to cover an entire installation, a group of sources or individual sources depending on regulations and site conditions. Facilities which fall below the various permitting thresholds are not required to obtain a permit, however may have to obtain one for individual sources.

Operational changes on the installation may require new permits and/or modifications of existing permits. Examples include construction of new air pollution sources, mission changes (increased or decreased activity), regulatory changes, removal, replacement or reconstruction of existing equipment, administrative (name or commander) changes, and process or material changes. The permitting process is neither static, nor consistent across all Air Force installations and will vary depending on the location of each installation and geographically separated unite (GSU). Each permitting agency will have their own permitting processes and steps, which must be followed. Therefore, the Air Quality Program Manager at each installation should be familiar with the permitting process of their relevant state and local agencies.

New Source Review (NSR) Permitting Programs (Construction or preconstruction permitting)

This CAA program requires certain stationary sources of air pollution or modifications to existing stationary sources to obtain an air permit prior to construction of a regulated source. The permit will specify the types of air pollution control devices to used, emission limits, and operational requirements for the source/facility. The NSR program provides for public participation in the permitting process, and typically requires at least 30 days for public comment on all draft NSR permits. There are three types of NSR permitting requirements and a source may have to obtain one or more of the following:

1. Prevention of Significant Deterioration (PSD): The CAA requires new or modified major stationary sources in attainment areas, or areas that meet (are designated as in attainment for) the National Ambient Air Quality Standards (NAAQS), to obtain a PSD prior to construction. "Unclassifiable Areas", or areas where the air quality data is insufficient to designate attainment or non-attainment status, are also included in the PSD Permitting Program. The purpose of this program is to ensure that air quality does not suffer from the addition of new or modified major sources of air pollution in these areas. Facilities must use best available control technology (BACT) to minimize their emissions.

2. Non-Attainment New Source Review (NA NSR): The NA NSR program applies to major sources in non-attainment areas, where air quality exceeds one or more of the NAAQS. The purpose of this program is to bring air quality in these areas into attainment of the national standards, without blocking economic development. To do this, the NA NSR program has lower thresholds triggering NSR permitting requirements and requires facilities to use the lowest achievable emission rates (LAER). LAER is the EPA’s strictest pollution control requirement. The NA NSR program may also require facilities to offset their emissions through a Cap and Trade program or other emissions offsetting actions.

3. Minor NSR: For new facilities or modifications to existing facilities where emissions increases are not large enough to meet the emission thresholds for the major NSR permitting requirements described above, each state has EPA-approved minor NSR programs, which can vary considerably from state to state or region to region.

Operating Permits Programs

The requirements of the Federal operating permits program are defined within Title V of the CAA. Title V operating permits are legally enforceable documents issued to major stationary sources of air pollution after the source has begun to operate. Sources with potential emissions greater than the established applicable Title V permitting thresholds or that meet other specific criteria must obtain an operating permit. These permits will outline the air pollution control requirements applicable to the covered source(s), including requirements from NSR permits, or other applicable requirements; such as New Source Performance Standards (NSPS) or National Emissions Standards for Hazardous Air Pollutants (NESHAP). Permit documents will describe specific conditions under which the installation must operate and outline any monitoring and reporting requirements along with payment of required fees. All permit and emissions fees must be included as part of the installations environmental budget process.

The Title V Operating Permits Program provides for public participation in the permitting process. The public generally has at least 30 days to provide comments on all draft Title V operating permits. For permits issued by a state or local authority, the EPA has a 45-day review period, which may or may not run concurrently with the public comment period.

During the NEPA process, the installation Air Quality Program Manager and the Air Force Civil Engineer Center (AFCEC) identify permit requirements. Most regulatory agencies have a web which will provide guidance and documentation for their permitting process, including the appropriate applications, forms and required documentation. It is typically advantageous to contact the applicable regulatory agency prior to beginning the permitting process in order to facilitate expedient and uneventful permit issuance or renewal.

Existing permits may have a fixed term or specific expiration date; the installation Air Quality Program Manager/AFCEC should initiate renewal action well in advance of the permit expiration date IAQ the requirements of their regulatory agency.

AFCEC/

Environmental Directorate

(CZ) and Regional

Environmental Office (REO)

AFCEC/CZ and the REO provide support to the Base Air Quality Program Manager and IST on determining appropriate regulations, determining whether a new permit or modification of permit is required, and determining permit type.

Installation Support Team

(IST)

The IST works with the Base Air Quality Program Manager to determine appropriate regulations, determine whether a new permit or modification of permit is required, and determine permit type.

Base Air Quality

Program Manager

The Base Air Quality Program Manager receives notification of new or changed sources or requirements, gathers the necessary documentation for those sources and compares it against regulatory requirements in order to determine the type of permit required in conjunction with the IST.

The Base Air Quality Program Manager has primary responsibility for determining appropriate regulations, determining whether a new permit or modification of permit is required, and determining permit type.

Step 1.3.1 – Revise PTE at a minimum of every three years

The Base Air Quality Program Manager revises the PTE at a minimum of every three years. This may reveal new or changed sources and requirements.

Proceed to Step 1.3.1 and Step 1.3.2.

Step 1.3.2 – Receive notification of new or changed source

The process for determining the type of permit required begins when the Base Air Quality Program Manager receives notification of plans to install a new source, modify or remove an existing source or plans to alter base operations which would impact air emissions.

Proceed to Step 1.3.4.

Step 1.3.3 – Receive notification of new or changed requirement

The process for determining the type of permit required can also begin when the Base Air Quality Program Manager receives notification of a new or changed requirement.

Proceed to Step 1.3.4.

Step 1.3.4 – Collect specification and operational data for source

When a new or changed source(s) or requirement(s) requires that a permit applicability determination be performed, the Base Air Quality Program Manager collects the necessary specification and operational data as required for the source(s) in question to be used to determine regulatory applicability and if a new permit, or modification of an existing permit is necessary and what type of permit would be required. Much of the data necessary for existing sources is gathered during development of the installations Air Emissions Inventory, however collection of information for new and proposed sources will come from project documents provided by the base Civil Engineering office and/or 813 forms. Information for new and replacement sources may require additional research and document gathering efforts including but not limited to contacting equipment manufacturers to identify equipment specifications and operational parameters for base level operations personnel. Regardless of source, all relevant data and source documentation, should be entered into and maintained in the Air Program Information Management System (APIMS).

Proceed to Step 1.3.5.

Step 1.3.5 – Determine applicable regulations Role: AFCEC/CZ and REO, IST, and Base Air Quality Program Manager

Entry from Process 1.1 Establish Strategic Plan and Process 2.1 Manage AEI.

The Base Air Quality Program Manager, in conjunction with the IST, reviews federal, state, and local regulations to determine which regulations are applicable to identified sources. The Base Air Quality Program Manager and IST reach back to AFCEC/CZ and the REO for support. There may also be potential coordination with the regulatory agency.

Proceed to Step 1.3.6.

Step 1.3.6 – Review source thresholds and performance standards

The Base Air Quality Program Manager and IST review source thresholds and performance standards including NSPS and NESHAP, reaching back to AFCEC/CZ and REO as needed.

Proceed to Decision 1.3.7.

Decision 1.3.7 – Is a new permit or modification required?

The Base Air Quality Program Manager, in conjunction with the IST, determines if a new permit or a modified permit is required. The Base Air Quality Program Manager and IST reach back to AFCEC/CZ and the REO for support. There may also be potential coordination with the regulatory agency.

If ‘Yes,’ proceed to Step 1.3.8.

Step 1.3.8 – Determine permit type(s)

Using the information on the data source and applicable regulations, the IST and Base Air Quality Program Manager perform source threshold analysis and determine the type of permit that applies to the new or modified source or requirement. Possible permit types include but are not limited to:

• Title V

• Minor Source

• PSD

• NSPS

• Synthetic Minor

• Non-attainment NSR

• GHG Tailoring Rule

• Other state or regional permits

The Base Air Quality Program Manager and IST reach back to AFCEC/CZ and the REO for support. There may also be potential coordination with the regulatory agency.

After identifying the permit type, IST and the Base Air Quality Program Manager proceed to creating/modifying the permit and to monitoring and recordkeeping.

Proceed to Process 1.4 Create New or Modify Permit.

Proceed to Process 2.3 Complete and Submit Reports.

Air Quality Program Management – (Plan) – 1.3 Determine Type of Permit Required a s e

A ir Q u a lit y P ro g ra m

M a n a g e r

IS

T A

F C

E C

/C Z a n d R

E O

Establish

Strategic

Plan

1.1

Manage AEI

2.1

Is a new permit or modification required?

1.3.7

Receive notification of new or changed requirement

1.3.3

Receive notification of new or changed source

1.3.2

Collect specification and operational data for source

1.3.4

Determine applicable regulations

1.3.5

No

Create New or Modify

Permit

1.4

Conduct

Monitoring and Maintain

Records

2.8

Determine permit type(s)

1.3.8

Yes

= Predefined Process

= Decision Point

= Manual Activity

Shape Key

= On-Page Connector

= Out of Scope Process

= Off-Page Connector

= Start & End

= Automated Activity

= Document

Start

Review source thresholds and performance standards

1.3.6

Revise PTE at a minimum of every three years

1.3.1

Complete and Submit

Reports

2.3

1.3.3

1.3.1

Air Quality Program Management – (Plan) – 1.4 Create New or Modify Permit

The Base Air Quality Program Manager is the lead responsible for the creation of all new or revised permit applications.

The Base Air Program Manager identifies the need for new permits. He should attend all relevant project meetings and keep the Installation Support Team (IST) up to date on progress until permit application is submitted to and approved by the permitting agency.

The permitting process varies between regulatory agencies, so the requirements will potentially be different between each installation and geographically separated unit (GSU) depending on their location. Since each agency has their own permitting processes and steps, the Base Air Quality Program Manager should become familiar with the requirements put in place by their regulator and relevant state and local agencies. The Base Air Quality Program Manager and IST coordinate with the Regional Support Team (RST), the Air Force Civil Engineer Center (AFCEC)/ Environmental Directorate (CZ) and the Regional Environmental Officer (REO) as necessary to ensure that unnecessary permits are not being requested or issued.

This process provides the steps to ensure that a new permit application or modification is created properly, the application is successfully submitted, and the approved permit is coordinated with the other existing permits on the base so as to maintain all operations in accordance with all statutory requirements.

Regulator/Agency The regulator/agency provides guidance and develops permit conditions and limitations. The regulator/agency also determines whether to approve the permit application.

AFCEC CZ and

REO

AFCEC/CZ and REO provide support to the Base Air Quality Program Manager and IST in researching the permit application process, validating source data, and developing the permit application.

IST ST works with the Base Air Quality Program Manager to research the permit application process, validate the source data, and develop the permit application.

Installation Commander

The Installation Commander approves and signs the permit application before it goes to the regulator/agency.

Base Air Quality Program Manager

The Base Air Quality Program Manager, in conjunction with AFCEC IST, researches the permit application process, validates source data, and develops the permit application in accordance with regulations. The Base Air Quality Program Manager also reviews the permit application, provides the application to the public for comments, and submits the application to the regulator/agency for approval.

Entry from Process 1.3 Determine Type of Permit Required.

Step 1.4.1 – Research permit application process

The Base Air Quality Program Manager and IST research the permit application process, reaching back to AFCEC/CZ and the REO for support.

Proceed to Step 1.4.2.

Step 1.4.2 – Validate source data and request additional information as needed

Role: AFCEC/CZ and REO, AFCEC IST, and Base Air Quality Program Manager

The Base Air Quality Program Manager and the IST review and validate the existing permit application/updates/renewal. The Base Air Quality Program Manager and the IST validate the source data available in the Air Program Information Management System (APIMS) and any additional data from the installation and requests additional information about the source if needed. They reach back to AFCEC/CZ and the REO for support as needed.

Proceed to Step 1.4.3.

Step 1.4.3 – Provide additional information as required and coordinate with IST

The Base Air Quality Program Manager provides additional permit application information to AFCEC IST along with comments as needed.

Proceed to Step 1.4.4.

Step 1.4.4 – Develop permit application per applicable regulations

The Base Air Quality Program Manager and IST prepare the permit application by filling out the required forms, gathering all specification and data sheets necessary for calculating the potential to emit (PTE) for the equipment requiring the permit, and reviewing all applicable regulations. They may also perform modeling as necessary. They reach back to AFCEC/CZ and the REO for support.

Proceed to Step 1.4.5.

Step 1.4.5 – Review permit application in coordination with appropriate stakeholders

The Base Air Quality Program Manager reviews the permit application with appropriate stakeholders, including the requestor of the permit, the generating activity, and installation Judge Advocate (JA). Any issues should be addressed during this step in order to improve the permit application.

Proceed to Decision 1.4.6.

Decision 1.4.6 – Approve?

Once the Base Air Quality Program Manager sends the permit application to the Installation Commander, the Installation Commander determines whether to sign and approve the application or not approve. If the responsible official grants approval, the Base Air Quality Program Manager submits the permit application to the relevant agency for approval. If the responsible official does not approve the application, then the AFCEC IST and Base Air Quality Program Manager revise the application accordingly.

If ‘Yes,’ proceed to Step 1.4.7.

If ‘No,’ proceed to Step 1.4.4.

Step 1.4.7 – Sign permit

The Installation Commander signs the approved permit.

Proceed to Step 1.4.8.

Step 1.4.8 – Submit to agency for approval and pay application fees as required

The Base Air Quality Program Manager submits the permit application to the appropriate regulatory/agency with all necessary supporting documentation and pays application fees as required. The appropriate regulator or agency depends on the location of the facility or GSU and the nature of the permit. Application fees vary for each agency; if the Base Air Quality Program Manager is not sure of the application fee or other details, he should contact the permitting agency for assistance.

Proceed to Decision 1.4.9.

Decision 1.4.9 – Approve?

The regulatory agency either approves or does not approve the permit application. If the regulator/agency approves the application, the Base Air Quality Program Manager can proceed to implementing the permit. If the regulator/agency does not approve the application, the AFCEC IST and Base Air Quality Program Manager revise and review as necessary.

If ‘Yes,’ proceed to Step 1.4.10.

If ‘No,’ proceed to Step 1.4.4.

Step 1.4.10 – Conduct public review and comments period as required

The Regulator/Agency submits proposed permit for public review as required by the permit application process.

During this period, the appropriate stakeholders accept comments from the public, respond to the comments, and modify the proposed permit and/or permit requirements as required.

Proceed to Step 1.4.11.

Step 1.4.11 – Review permit requirements

The Base Air Quality Program Manager reviews the permit requirements included in the approved permit and prepare the applicable source and operations for compliance with those requirements.

Proceed to Decision 1.4.12.

Decision 1.4.12 – Are emission sources properly configured in APIMS?

The Base Air Quality Program Manager is responsible for ensuring that emission sources are properly configure in APIMS to allow for compliance tracking and determinations to be made against final permit requirements. If the sources are properly configured in APIMS, the Base Air Quality Program Manager develops an implementation strategy to comply with permit requirements. If sources are not properly configured, then the Base Air Quality Program Manager proceeds to Process 2.1.2 Configure Emissions Source.

If ‘Yes,’ proceed to Step 1.4.13.

If ‘No,’ proceed to Process 2.1.3 Configure Emissions Source and Out-of-Scope Process Identify Issues and Include in Appropriate AMP.

Process 2.1.3 – Configure Emissions Source

This process describes the steps involved in configuring a stationary or mobile source in APIMS. For more information, please proceed to Process 2.1.3 Configure Emissions Source.

Proceed to Step 1.4.13

Step 1.4.13 – Develop implementation strategy

Entry from Process 2.1.3 Configure Emission Source.

The Base Air Quality Program Manager develops the implementation strategy that will ensure compliance with the requirements of the new or modified permit. This involves including any issues in the appropriate Activity Management Plan (AMP) and ensuring significant Environmental Management System (EMS) aspects are posted to the base EMS. The Base Air Quality Program Manager can then move onto implementing the permit in the “Do” phase.

Proceed to Decision 1.4.14.

Decision 1.4.14 – Create electronic record for new permit or renewal?

The…