ID07180034_Supporting_Documents_Part_1.pdf

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2 Inch

Pressure Decay

TP201.3

Ref. No.: Testing Company

AQMD Id:

Site Name: Name:

Address: Address:

Phone: Phone:

Phase I System? Tanks Manifolded?

Phase II System? Vapor Pot Present?

Total # of Nozzles 1 1

Products per Nozzle 1

Tank Information 1 2 3 4 All

1. Product Grade 87 / Mogas 87 / Mogas

2. Actual Tank Capacity, gallons 500 500

3. Gasoline Volume, gallons 214 214

4. Ullage, (V) gallons (line #2 minus line#3) 286 286

Test Information 1 2 3 4 5

5. Start time 9:35am 9:35am

6. Initial Test Pressure, inches H2O 2.00 2.00

7. Pressure after 1 minute, inches H2O 1.92 1.92

8. Pressure after 2 minutes, inches H2O 1.81 1.81

9. Pressure after 3 minutes, inches H2O 1.70 1.70

10. Pressure after 4 minutes, inches H2O 1.61 1.61

11. Pressure after 5 minutes, inches H2O 1.54 1.54

12. Allowable Final Pressure 0.90 0.90

13. Pass / Fail (Enter "GF" for Gross failure) Pass Pass

Requested Test Date.

Requested Test Time.

What type of pressure device used?

Calibration date for pressure device (90 days).

Enter initial tank ullage pressure (Vent if over 0.5 in. w.c., then start the 30 min no dispensing period)

Enter flowmeter rate, F (Must be 1 to 5 CFM).

Calculate ullage fill time, t2. t2= V

Actual Fill Time [1522]F

Enter ending value of drift test (Must be 0.01 in. w.c. or less).

Record Vapor Coupler Integrity Test Assembly pressure after 1 minute and location.

Nitrogen introduction point. Phase I vapor coupler or Phase II vapor riser?

Tester:

Signature: Test Date:

Dist. Permit:

12 seconds

Tester ICC:

MANOMETER

2.00

N/A

0.00

Total # of Tanks

12/8/2017

0.00

3 CFM

Phase 1

9:00am

03 seconds

1/10/2018

(530)634-2844

1/10/2018

N/A unknown

Beale AFB

Building #1324

5254736

Morrison Bros / VR-402

#P90949

RICHARD THOMAS

N/A

N/A

CGRS, Inc

5444 Dry Creek Rd

Sacramento, CA 95838

916-991-1100

Beale AFB, CA 95903

Updated 04/19/06 TATT Team

2 Inch

Pressure Decay

TP201.3

Ref. No.: Testing Company

AQMD Id:

Site Name: Name:

Address: Address:

Phone: Phone:

Phase I System? Tanks Manifolded?

Phase II System? Vapor Pot Present?

Total # of Nozzles 1 1

Products per Nozzle 1

Tank Information 1 2 3 4 All

1. Product Grade 87 / Mogas 87 / Mogas

2. Actual Tank Capacity, gallons 550 550

3. Gasoline Volume, gallons 230 230

4. Ullage, (V) gallons (line #2 minus line#3) 320 320

Test Information 1 2 3 4 5

5. Start time 10:10am 10:10am

6. Initial Test Pressure, inches H2O 2.00 2.00

7. Pressure after 1 minute, inches H2O 1.86 1.86

8. Pressure after 2 minutes, inches H2O 1.73 1.73

9. Pressure after 3 minutes, inches H2O 1.71 1.71

10. Pressure after 4 minutes, inches H2O 1.62 1.62

11. Pressure after 5 minutes, inches H2O 1.59 1.59

12. Allowable Final Pressure 0.20 0.20

13. Pass / Fail (Enter "GF" for Gross failure) Pass Pass

Requested Test Date.

Requested Test Time.

What type of pressure device used?

Calibration date for pressure device (90 days).

Enter initial tank ullage pressure (Vent if over 0.5 in. w.c., then start the 30 min no dispensing period)

Enter flowmeter rate, F (Must be 1 to 5 CFM).

Calculate ullage fill time, t2. t2= V

Actual Fill Time [1522]F

Enter ending value of drift test (Must be 0.01 in. w.c. or less).

Record Vapor Coupler Integrity Test Assembly pressure after 1 minute and location.

Nitrogen introduction point. Phase I vapor coupler or Phase II vapor riser?

Tester:

Signature: Test Date:

Dist. Permit:

14 seconds

Tester ICC:

MANOMETER

2.00

N/A

0.00

Total # of Tanks

12/8/2017

0.00

3 CFM

Phase 1

10:00am

04 seconds

1/10/2018

(530)634-2844

1/10/2018

N/A unknown

Beale AFB

Building #2240 Golf Course

5254736

G-70-102-A

#P90949

RICHARD THOMAS

N/A

N/A

CGRS, Inc

5444 Dry Creek Rd

Sacramento, CA 95838

916-991-1100

Beale AFB, CA 95903

Updated 04/19/06 TATT Team

1135546719C Highlight

Air Force-Wide Air Quality Fundamentals and Emerging Issues

Beale AFB

August 25, 2015

Objectives

• Discuss general fundamental air quality compliance best practices

• Discuss recommendations for handling related emerging issues

Organization of Presentation

• Introduction to air quality issues and regulation

– - Classes of pollution, regulatory frameworks, and control strategies

• Fundamental compliance best practices

• Handling of emerging issues

Four Classes of Air Pollution

1. “Criteria” air pollutants

2. Hazardous air pollutants (HAPs)/Toxic Air Contaminants (TACs)

3. Ozone depleting substances (ODS)

4. Greenhouse Gases (GHGs)

1. Criteria Air Pollutant Regulation - Overview

• Regulation based in part on concentrations measured in the ambient air

• EPA sets National Ambient Air Quality Standards (NAAQS) – “protective of public human health and welfare”

• Regulations are set up to attain the NAAQS by specific statutory deadlines

• EPA also develops New Source Performance Standards (NSPS)

Flow-down to State/Local Agencies

• Designate areas as “attainment”/”unclassifiable” or “nonattainment” based on air quality monitoring data

• State/local agencies prepare “State Implementation Plans” (SIPs)

– Air emissions inventory (AEI)

– Nonattainment areas need to develop regulations to reduce the inventory

• Failure to attain the NAAQS by the statutory deadline can result in loss of Federal highway funding

Air Pollution

Regulatory “Chain of Command”

US CONGRESS

CLEAN AIR ACT (LAW)

(REGULATIONS)

STATE LEGISLATURE

(LAWS)

(REGULATIONS)

(REGULATIONS)

How Are Emissions Inventoried?

• “Stack tests”, research programs, engineering calculations for determining emission factors; e.g.

– Pounds of emissions per hour of operation

– Pounds per horsepower-hour of engine operation

– Pounds per gallon of fuel used

– Pounds per gallon of coating applied

• Emission factors are then multiplied by activity data

– hours of operation, gallons of fuel used, gallons of coatings used, etc.

What Are the Criteria Air Pollutants?

Carbon Monoxide (CO) Sulfur Dioxide (SO2) Nitrogen Dioxide (NO2)

Criteria Pollutants

Lead (Pb)

Ozone (O3)

Formed Primarily By

Air emissions from combustion

(Misc. sources not present at most AFB)

Fine Particulate Matter (smaller than

0.0025 mm) (PM2.5) Respirable Particulate Matter (smaller than 0.01 mm) (PM10)

Road dust and earth disturbance;

mechanical processes

Evaporation of organic liquids (gasoline, solvents, personal products, etc.) – “volatile organic compounds” (VOC)

Ammonia

RED: Criteria pollutant is formed by reactions in the air (secondary formation)

Different Averaging Times for Different NAAQS

Criteria Pollutant NAAQS

Ozone Annual fourth-highest daily maximum 8-hr average concentration, averaged over 3 years, ≤ 0.075 ppmv (75 ppbv)

Nitrogen Dioxide (NO2) 98th percentile of 1-hour daily max. concentrations (averaged over 3 yrs) ≤

0.100 ppmv (100 ppbv) Annual mean ≤ 0.053 ppmv (53 ppbv)

Fine Particulate Matter (PM-2.5) 98th percentile of the 24-hour average (averaged over 3 yrs) ≤ 35 µg/m3

Annual mean (averaged over 3 yrs) ≤ 12 µg/m3

Respirable PM (PM-10) 24-hour average ≤ 150 µg/m3 except once per yr (averaged over three years)

Sulfur Dioxide (SO2) 99th percentile of 1-hour daily max. concentrations (averaged over 3 yrs) ≤

0.075 ppmv (75 ppbv) 3-hour average ≤ 0.5 ppmv except once per year

Carbon Monoxide (CO) 1-hr average ≤ 35 ppmv except once per year 8-hr average ≤ 9 ppmv except once per year

Lead Rolling 3-month average ≤ 0.15 µg/m3

Criteria Pollutant Control Techniques

• Don’t make the pollutant in the first place (lower-emitting equipment/processes)

• Use “add-on” equipment to oxidize, reduce, and/or capture

– Oxidize CO, VOC, and PM to carbon dioxide (CO2)

– Reduce NOx to nitrogen (N2)

– Capture SO2, PM, ammonia, Pb (and reuse or dispose of)

– For sources emitting high concentrations of VOC, some controls capture and recover (recondense) the VOC

U.S. Trends in Emissions And Other Factors, 1970-2013

Source: US EPA, http://www.epa.gov/airtrends/images/y70_13.png

Regulatory Framework

• Regulatory agencies largely address stationary sources of air pollution through the issuance of permits to facilities

– Preconstruction permits for new construction and modifications (incorporate NSPS, although NSPS can also apply to unpermitted sources)

– Operating permits

• Mobile sources largely addressed at the Federal level by requiring manufacturers to sell cleaner vehicles, fuel suppliers to sell cleaner fuels

– California is an exception – more on this later

• If a Federal approval is required and the area is or was a nonattainment area, emissions (stationary and mobile) not covered by a permit can trigger “General Conformity” regulatory requirements

• Standards for VOC in consumer products, paints, et.

Elements of Stationary Source Permit Applications

• Permit application requirements can depend on several things, including where you are, how large the project or facility is, etc.

• All applications require you to quantify “Potential to Emit” (PTE) for the project and/or facility

• Some will require you to comply with a control technology requirement (e.g., “Best Available Control Technology”)

• Some will require you to purchase emissions “offsets”

• Some will require you to conduct dispersion modeling

Why is PTE Important?

• PTE largely dictates what the other application requirements will be

• Key questions:

– Is your facility a major source?

– (For preconstruction permits:) Is your project a major modification?

• “Major” varies from regulation to regulation and pollutant to pollutant but is generally based on the annual PTE

What is PTE?

• Potential To Emit (PTE) also called Potential Emissions

• “Maximum capacity of a source to emit…under its physical and operational design….”

• “….Any physical or operational limitation…including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation is enforceable.”

Quantifying PTE

• Typical default is to assume that equipment operates at its maximum hourly firing rate for 24 hours/day, 365 days/yr (= 8760 hr/yr)

– You can identify restricted hours, but then you’ll be held to them and asked to track them

• If you ran an engine for ten hours in a year but its permit allows it to run for 50 hours in a year, PTE is based on 50 hours of operation

Key Cutpoints for Determining if a Facility is a “Major

Source” of Criteria Pollutants

• In attainment/unclassified areas (that were never nonattainment), stationary source PTE ≥ 100-250 TPY

• In nonattainment areas, the “major source threshold” can be as low as 10 TPY for the nonattainment pollutant (or its precursors); it depends on how bad the nonattainment is (extreme, severe, serious, moderate, or marginal)

• Always check state/local regulations to confirm thresholds

Major Modifications

• A major modification that by itself would trigger major source thresholds is major, regardless of whether the facility being modified was major or not

• Otherwise, major modifications are only those that are conducted at facilities that are major sources and are “significant” (thresholds are lower for major mods than for major sources; e.g., 10 TPY for PM-2.5, 40 TPY for NOx/SO2/VOC)

– Complex analysis; can take credit for reductions in actual emissions

Federal Regulations Define “Facility” As:

• A stationary source or group of stationary sources (facility)

– Located within a contiguous area;

–And “Under Common Control”;

– Sources should “belong to the same industrial grouping”

Is A DoD Base a Single Facility?

• Not necessarily:

– For Beale AFB, EPA identified that the PAVE PAWS radar facility is a separate facility from the rest of the base

– For Elmendorf AFB in Alaska, EPA allowed for the base to be considered as 11 separate facilities, separating out AAFES gas stations and other facilities (10/5/99 Bray memo)

• EPA has guidance specific to military bases (8/2/96 Seitz memo, available from http://www.epa.gov/region7/air/title5/t5memos/dodguid.pdf)

– Note: “it is not intended to [supersede] or replace more stringent approaches taken by any particular…permitting authority provided there is a rational basis for the treatment of military installations…”

Preconstruction Permitting

• Generally referred to as “New Source Review” (NSR)

• Federally mandated NSR programs cover both major sources and major modifications but many state/local agencies (esp. in California) have their own minor source NSR programs that are based in part on the Federal ones

• Two main permitting programs:

– Prevention of Significant Deterioration (PSD)

– Nonattainment New Source Review (NNSR)

PSD

• Only applies to new major sources of attainment/unclassifiable pollutants (and their precursors) or major modifications

• Requires application of “Best Available Control Technology” (BACT) (possibly on some pollutants that didn’t trigger the permitting)

• Requires dispersion modeling to show compliance with both NAAQS and PSD increments

– Can be very extensive

– May require modeling of other nearby facilities

– Special considerations if Federal “Class I” areas are nearby (designated wilderness areas/parks); “visibility”

What’s BACT?

• Formally, involves a “top-down” of emissions control options, evaluating the most stringent ones for technical feasibility and economic feasibility

• “BACT Clearinghouses” exist at both Federal and State/local levels

• In practice, for some common source types, can be agreed upon with the agency in a preapplication meeting without having to do a formal analysis

• Can’t be any less stringent than an applicable NSPS

What’s Dispersion Modeling?

• Means of translating emissions out a stack (or several sources) into pollutant impacts (concentrations) at nearby locations

– Must show compliance with NAAQS

– Some agencies/programs require analysis of impacts at any point off-site; some require analysis only at places where people are likely to be (residences, offices, parks, etc.)

– No widely accepted models for secondary pollutant formation

• “Screening” modeling can be done quickly but is very conservative

• “Refined” modeling requires obtaining meteorological data from nearby meteorological stations, getting it formatted for modeling, etc.

• May need to consider background concentrations

Nonattainment NSR

• Only applies to new major sources of nonattainment pollutants (and their precursors) or major modifications

• Requires that the project have the “Lowest Achievable Emissions Rate”

(LAER)

– Similar to BACT, except that economic in feasibility can’t be used to dismiss LAER

• Requires emissions offsets

What Are Emissions “Offsets”?

• Basically these are credits that sources generate for shutting down a source or reducing emissions from a source, beyond what is required by permitting/rules

• Sources subject to nonattainment NNSR need to offset emissions increases by purchasing offsets, sometimes at more than a 1:1 ratio (depends on degree of nonattainment)

• Often done through emissions brokerages for major sources; some air districts have “banks” for minor sources

• Supply constraints can make these very expensive (or in some cases none are available – but agencies have workarounds)

Remember How PTE Is Defined

• Includes consideration of control equipment

• So if you know you’re going to have to apply controls—or know that if you don’t, you’ll trigger a major source permitting threshold— recalculate PTE after taking the control device into account

• Example: uncontrolled PTE is 10% over a major source/mod threshold and BACT/LAER is going to require 90% control

– You can apply controls to reduce PTE by 30%, not trigger the major source/mod threshold, and then not be subject to BACT/LAER (unless the state/local agency requires it for minor sources/mods)

Federal Operating Permits

• Federal Operating Permit program is called “Title V” or “Part 70”

• Triggered by emissions ≥ 100 TPY

• Not supposed to add/trigger any requirements (except possibly monitoring requirements), but supposed to incorporate all applicable requirements

• Requires all records be kept for 5 years and renewal every 5 years

• Relatively onerous to modify

– Extensive review by both public and US EPA before a significant modification can be approved

Elements of Stationary Source Permits

• Emissions control requirements (including operating practices)

• Periodic testing of emissions

• Continuous or semi-continuous monitoring of emissions (using a continuous emissions monitor) or parameters indicative of emissions (e.g., pressure drop across a baghouse)

• Recordkeeping (“activity data”, evidence that equipment is operated and maintained properly, etc.)

• Reporting (routine periodic, and sometimes episodic)

Which Agency Am I Dealing With for Permitting?

• For minor sources, typically the state/local agency

• For major sources/mods, either the state/local agency or US EPA (http://www.epa.gov/nsr/where.html)

• In California, the state/local agency you deal with will be the local air district rather than California ARB

“Conformity”

• Conformity refers to a project’s conformity with a SIP and emissions budgets in the SIP; applies only to nonattainment areas or “maintenance areas” (attainment, but previously nonattainment)

• Transportation conformity (40 CFR 93 Subpart A) is for transportation plans/programs/projects (e.g., highways, etc.)

• General conformity (40 CFR 93 Subpart B) is for everything else

– Basically “picks up” any projects requiring Federal approval not covered by stationary source permitting, including sources involving significant emissions mobile sources (including but not limited to construction sources)

General Conformity

• If emissions can be shown to be below major source thresholds (essentially the same as Federal NNSR thresholds) then no formal conformity “determination” needs to be made

• If emissions exceed thresholds, an approving Federal agency needs to make a determination that the project conforms, e.g. by

– Purchasing emissions offsets

– Having the project explicitly included in a SIP

– Dispersion modeling evaluations (only available for some pollutants)

• Tool is available to bases for this evaluation

Which Agency Am I Dealing With for General Conformity?

• In general, one of the Federal agencies from which an approval is needed – often not EPA

• That being said, common practice is for the project proponent to prepare a General Conformity “support document” that lays out all of the quantitative information regarding emissions (that the approving agency will need to make a conformity determination)

National Environmental Policy Act (NEPA)

• Associated regulations at 40 CFR 1500-1508

• Even though this is a general environmental statute that applies to projects, it can end up requiring additional air analyses beyond what the Clean Air Act requires

• For example: dispersion modeling evaluation of combined impacts of stationary and mobile sources of air pollution

2. Hazardous Air Pollutants (HAPs)/

Toxic Air Contaminants (TACs)

• Includes “substances…known or reasonably anticipated to be carcinogenic, mutagenic, teratogenic, neurotoxic, which cause reproductive dysfunction, or which are acutely or chronically toxic”

• HAP is the term used in the Federal 1990 Clean Air Act Amendments

– Listed 189 HAP, but since some of the things listed are categories of chemicals, the list includes thousands of substances

– No Federal ambient standards / Federal rules do not identify any “safe” concentration

– Universal “major source” definition for HAP: PTE of 25 TPY, or 10 TPY for any one HAP; nonmajor sources called “area sources”

• California regulates TAC, which includes several additional substances

Issues Common to Criteria Pollutants and HAP/TAC

• Control options are largely the same (most HAP are also VOC or

PM)

• Dispersion modeling used to relate emissions to impacts (but not required by Federal Clean Air Act)

HAP Regulatory Framework (Federal)

• Similarities to criteria pollutants (HAPs are addressed in permits for stationary sources, mobile sources regulated largely at manufacturer/fuel provider level) but do not themselves trigger PSD or

NNSR

• No HAP “offsets”

• Key issue is that there are also “NESHAP”/”MACT”/”GACT” standards (40 CFR 61/63) that can apply to existing sources (even if not modified) and new sources regardless of whether they need permits or not

– These standards also get updated

– Several of these have not been delegated to state/local agencies to enforce

Typical Federal MACT/GACT Framework

• For a new/newly revised standard

– Send an Initial Notification (IN) to agency (US EPA, and state/local agency if delegated) identifying you have a source subject to the standard

– Typically three years to comply

– Sent a Notice Of Compliance Status (NOCS) by the compliance deadline that identifies compliance

• Note that MACT/GACT standards also cross-reference some (but typically not all) requirements in 40 CFR 63 Subpart A

State/Local Metrics for Evaluating Toxics

• Typically applied to results of dispersion modeling (i.e.., maximum concentrations predicted at receptors)

• Carcinogens: “Lifetime Cancer Risk” (x-in-a-million)

– Analyses can be simple (e.g., for each toxic, multiply concentration by state-identified “unit risk factor” to determine the x-in-a-million risk, then add up those risks for each toxic) or more complex (age-specific doses, multipathway analyses)

• Other pollutants: “Hazard Index” (unitless)

– Divide concentration of each toxic by its “reference concentration” (this is a “Hazard Quotient”)

– Add up all the HQs to get the HI

State/Local Regulation of Toxics

• May require implementation of BACT for toxics emissions

• May require permit applications to conduct dispersion modeling and either meet state-defined pollutant-specific limits or conduct a health risk assessment (HRA) to meet a state-defined limit (e.g., lifetime cancer risk of 10-in-a-million, hazard index of 1)

• California ARB develops Air Toxics Control Measures (ATCM) for stationary and mobile sources

California AB2588 Requirements

• California’s AB2588 “Hot Spots” rule requires tracking (at least quadrennially) of TAC emissions

– In California, diesel particulate matter (DPM) is often a major component of the total risk from all TACs

• Facilities are prioritized based on their TAC emissions and may be required to prepare quantitative health risk assessments (HRAs) – i.e.., dispersion modeling + calculation of risks (can include risks from both inhalation and other pathways, such as deposition onto food crops)

• If HRA indicates unacceptable risk, facilities may have to notify the public and prepare risk reduction plans

3. Ozone-Depleting Substances (ODSs)

• Refers to substances that deplete stratospheric ozone – important for protecting earth from sun’s rays

• Largely coolants/refrigerants;

“CFCs” regulated by Montreal Protocol and US EPA (40 CFR 82)

• Personnel conducting maintenance on this equipment need to be EPA-certified; minimize losses/dispose of properly

4. Greenhouse Gases (GHGs)

• Like ODS, a global issue; not localized like criteria/toxic pollutants

• IPCC “assessed that more than half of the observed increase in global average surface temperature from 1951 to 2010 is very likely [90-100% probability] due to the observed [man-made] increase” in concentrations of these three pollutants (AR5 TS, p. 66):

– Carbon dioxide (CO2)

– Methane (CH4)

– Nitrous oxide (N2O)

• Primarily regulated by US and California ARB, not air districts (except to the extent GHG BACT is required for a major source/mod permit)

Key GHG Reduction Measures

• There is no “catalytic converter”/“filter” for CO2 like there is for many traditional air pollutants

• More efficient fuel-burning equipment/vehicles, more energy-efficient buildings

• Fuel switching

– Typically, electric lower-emitting than natural gas, even when upstream emissions from power plant emissions are considered

– Gas lower-emitting than oil, oil lower-emitting than coal

– Biofuel

• Zero-emissions power (wind, solar, nuclear, hydrogen)

Trends in Average Global ODS and GHG Concentrations (source: IPCC 5th Assessment Report, WG 1 Ch 2)

Inventorying Greenhouse Gases (GHGs)

• Typically in metric tonnes (MT) rather than standard (“short”) tons

1 MT = 1.1 ton

• To account for differences in the significance of the different GHGs—i.e., methane and N2O are more potent than CO2—emissions of methane and N2O are multiplied by “Global Warming Potentials” to arrive at “CO2 equivalents” (CO2e)

• Issues:

– Different agencies use different GWPs

– Even for the same agency, GWPs get updated

Sample Calculation of CO2e

• Effective Jan. 1 2014, US EPA regulations (40 CFR 98) identify a GWP of 25 for methane and 298 for N2O

• Sample calculation for 50 MMBtu/hr gas-fired boiler:

Pollutant GWP

CO2 53.06 kg/MMBtu 2,653 kg CO2/hr 1 2,653 kg CO2e/hr

CH4 1.0E-03 kg/MMBtu 0.05 kg CH4/hr 25 1.3 kg CO2e/hr

N2O 1.0E-04 kg/MMBtu 0.005 kg N2O/hr 298 1.5 kg CO2e/hr

Total 2,656 kg CO2e/hr

Emission Factor × 50 MMBtu/hr CO2e

Regulation of Greenhouse Gases (GHGs)

• Currently somewhat following paradigms used for criteria pollutants/HAP

– PSD major facility permitting can require application of Best Available Control Technology (BACT) for GHGs if PTE increase is “significant” (75,000 TPY CO2e)

– Some related requirements in NSPS/MACT standards (e.g., efficiency evaluations)

– Mobile sources regulated at manufacturer level

• Key exception: there are reporting regulations that for which applicability is triggered by facilitywide actual (not potential) emissions (based on very specific emissions inventory procedures)

– Federal trigger: 25,000 MT CO2e/yr

– California trigger: 10,000 MT CO2e/yr (extensive accuracy/verification procedures)

• Plus California has a “Cap and Trade” program (25,000 MT CO2e/yr trigger)

California GHG Cap & Trade

• Cap and trade is a “market-based” program; principle is that sources are given allowances for actual emissions; they can choose to install control equipment or buy allowances from sources that don’t need all of them

• Idea is that the sources that are most cost-effective reductions will happen first

• Currently linked with Quebec, but no other states/provinces/countries

Sovereign Immunity and Antideficiency Act

• General concept: Federal agencies are not necessarily subject to all state/local rules, especially if there is no nexus to a Federal requirement; Federal employees cannot voluntarily go along with (or be “creating or authorizing an obligation under”) state/local requirements

• In general, any rule in a SIP has a nexus

• Nexus is less obvious for HAP, though most HAP are also criteria pollutants (VOC or PM)

• May be an issue for California GHG requirements

Common Compliance Challenges for DOD Facilities

• Large facility footprints

– Difficulty keeping track of all activities (including extensive contractor activities) at a site

– Variety of source types means a variety of applicable requirements

• Personnel turnover

• Constantly changing requirements from multiple agencies

• Requirements (or details of requirements) that aren’t shown in permits

• Regulatory ambiguity

Fundamental Compliance Best Practices

• Know what requirements currently apply and which ones you could run up against (know actual emissions and PTE)

• Have some type of compliance system; do internal audits

• Ensure that operators are trained; keep good records

• Purchase domestic/local paints, consumer products

• There is essentially always a general duty to minimize emissions

– For combustion sources: run them as the manufacturer specifies, look for signs of poor combustion (e.g., smoke, unusual sounds), don’t run them unnecessarily

– For evaporative sources: low-VOC materials, close lids, control fumes, etc.

• Don’t wait for noncompliance

Emerging Issues

• Across the country:

– Implementation of Boiler MACT and Engine (RICE) MACT

– New NAAQS, and associated requirements when areas are redesignated from “attainment” to “nonattainment”

– GHGs

• In California:

– Gasoline dispensing sources

– Portable engines/mobile sources and “Tactical Support” interpretations

– New Risk Management Guidelines (and associated requirements)

Boiler MACT and RICE MACT

• Complex rules with extensive applicability (affected existing boilers and engines across the country)

• RICE MACT

– Compliance deadlines for existing engines at area sources were in 2013

– Very limited requirements for emergency engines and engines < 300 hp at area sources

• Boiler MACT

– Compliance deadline for existing boilers at area sources: March 21, 2014

– Gas-fired boilers and hot water heaters exempt

• Various court challenges; in May 2015 the D.C. Circuit Court of Appeals held that EPA acted arbitrarily and capriciously in exempting emergency engines in demand-response programs from emissions control requirements

Ozone NAAQS Revisit

• November 2014: EPA proposed making the ozone NAAQS (0.075 ppm, annual fourth-highest daily maximum 8-hr average concentration, averaged over 3 years) more stringent (0.065-0.070 ppm, seasonal aggregate of weighted hourly concentrations observed between 8 am and 8 pm.)

• Once a new standard is finalized, areas will be designated as nonattainment/attainment and state/local agencies typically get three years to prepare SIPs

GHGs

• Quantitative performance standards for existing electricity generators have been developed (ESPS)

• Methane reduction initiatives

• Changing GWPs

– IPCC’s Assessment Reports (2nd/3rd/4th/5th) have updated GWPs (California uses 100-year GWPs from AR2; EPA uses those from AR4; Oregon is planning on using those from AR5)

– IPCC has noted that “[t]here is no scientific argument for selecting 100 [yr GWPs] compared with other choices [20 yr, 500 yr]”; introduced a different weighting factor, GTP; and for methane AR5 identifies weighting factors anywhere between 4 and 84

Gasoline Dispensing Facilities (GDFs)

• AAFES/retail facilities (> 100,000 gal/month)

– Not all California agencies have been enforcing the Federal requirement for triennial valve cracking pressure tests

• Small aboveground storage tanks (ASTs)

– Relatively inexpensive standing loss controls (SLCs) – paint, etc. – may reduce gasoline evaporative losses enough to pay for themselves

Engines Are Regulated by Usage Type

*If these engines stay at one spot for more than 12 months, they are “stationary” instead of nonroad/portable

“On-Road”

“Nonroad” (Federal definition)

“Stationary” (incl. all RPIE Generators

“Off-Road” (CA definition)

“Portable”* (CA definition)

(incl. EAID Generators

California Portable Engine Regulations (includes EAID Generators and any other portable engines)

• CARB has a voluntary Portable Engine Registration Program (PERP)

– Key benefit is to exempt registered engines from additional District regulation (e.g., permitting)

– Essentially zero operator requirements for engines considered “Tactical Support Equipment (TSE)”, aside from a prohibition on dark smoke and doing an inventory as of Dec. 31 of each year

– Beale currently has approximately 250 PERP engines (all identified as TSE except a wood chipper)

• CARB has a mandatory Air Toxics Control Measure (ATCM) for diesel PM from portable engines ≥ 50 bhp

– TSE are exempt

PERP “Validity” Issues/Permitting

• Guidance from California air districts issued in March 2014 takes more aggressive stance with regard to portable power generators in particular (requiring permits even if CARB registered them as PERP)

• L3 Vertex’s portable engines (not TSE) were required to obtain a district air permit for registered PERP

• District ordered contractors proposing to do work at PAVE-PAWS to get air permits for their PERP-registered engines (not TSE)

• District inspector asked about a Power Pro engine on site - initially stated that it was not TSE and that Beale needed to submit a permit application in two days

TSE Designation

• Recent guidance on this topic from DOD (not released to Tetra Tech)

• Tetra Tech’s recommendation is that the Power Pro engines not be considered TSE because:

– California districts, including FRAQMD specifically, are really focusing on electrical generators

– Thought it could be argued that they provide critical support for the base, support for TSE categorization is weakened by the fact that these are electrical generators used to provide building power, power for water/fuel pumping, etc. – applications not unique to the military (unlike FlightLine engines)

– Engines are also always on site, and can use California diesel (not using JP-8)

New AB2588 Risk Management Guidelines

• New Health Risk Assessment (HRA) methods are approximately 3x (or more) stringent than previous ones

• New prioritization guidelines being developed (due out in 2016)

• Likely to bump several facilities up from “low” priority to “medium”, “medium” to “high”

• Special risk assessment procedures being developed for emergency engines (due out in 2016)

Form 200 4/15 Permit Application Page 1 of 2

Butte County

AIR QUALITY MANAGEMENT DISTRICT

629 ENTLER AVENUE, SUITE 15 CHICO, CALIFORNIA 95928

TELEPHONE: (530) 332-9400 FAX: (530) 332-9417

1. APPLICATION TYPE AND FILING FEE: (See attached Instruction Sheet for more details.)

Authority to Construct (ATC) Permit $75 Permit to Operate $75 Request for Exemption $75 Transfer of Ownership $60 (List Permit to Operate No.: ) Permit Modification $75 (List Permit to Operate No.: ) Expedited ATC $75 (Only applies to short-term projects) Please Note: A valid ATC Permit or other form of written authorization from the Air Pollution Control Officer (APCO) must be received prior to accepting delivery of process equipment or air pollution control equipment at the proposed site of installation.

After an ATC Permit is granted for any equipment, deviations from the approved plans are not permissible without first securing additional approval for the changes from the APCO. Additional Authority to Construct and/or Permit to Operate fees will be assessed at the time of permit issuance. All fees are non-refundable.

2. CONTACT INFORMATION (Please type or print)

R E

SP

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(O

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/O

PE

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Company/Operator Name:

Contact Person & Title:

Mailing Address:

Phone :

Facsimile:

City, State, Zip:

E-Mail Address:

Employer Identification Number:

Standard Industrial Classification Code (If Known):

Type of Business:

Sole Proprietorship Limited Liability Company Partnership Government Corporation Wholly-owned Subsidiary Other:_____________________________

FA

C

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IT

Y

L O

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Name of Facility:

Street Address:

E- Mail Address:

Facsimile:

C O

N T

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C T

O R

IN

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M A

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Name of Contractor (If applicable):

Street Address:

E-Mail Address:

Facsimile:

BCAQMD USE ONLY RECEIPT NUMBER: DATE RECEIVED:

AMOUNT RECEIVED: APPLICATION NO:

Send Invoice to:

Responsible Company (Owner/Operator) Facility Location Contractor Other (Specify)_________________ Send copies of permit and correspondence to:

Responsible Company (Owner/Operator) Facility Location Contractor Other (Specify)_________________

PERMIT

Form 200 4/15 Permit Application Page 2 of 2

3. PROJECT INFORMATION:

Project Name:

Project Type:

Description of Equipment to be Installed or Activity to be Performed:

4. Supplemental Information Attached? No Yes Refer to Permit file (Please check applicable supplemental forms submitted) You may also access all of the supplemental forms at http://bcaqmd.org/forms-applications/stationary-sources/

Form # Name Form # Name 201 General Supplemental Information 225 Dehydrators 202 List of Criteria 226 Dry Cleaning Equipment 206 Public Notification 227 Gasoline Storage, Phase I & II Vapor Recovery 213 Abrasive Blasting (Confined) 230 Grain Processing 215 Aggregate Processing Plant 232 Crematory 216 Furnace 233 Incinerator 217 Asphalt Concrete Production 234 Internal Combustion Engines 218 Baghouse 236 Nut Processing 219 Boilers and Liquid Heaters 237 Ovens 220 Carbon Adsorption Unit 239 Soil Vapor Extraction 221 Spray Coating Operations 240 Soil Aeration 223 Cyclones Other (Specify):___________________________

5. Has work on this project begun or has the project been completed? No Yes ***Please Initial:______

6. Is the project located within 1,000 feet of the outer boundary of a school or school site? No Yes (If “Yes”, please contact the District for additional guidance.)

7. Are all major stationary sources (emissions more than 25 tons per year) owned or operated by applicant in California in compliance with all air pollution rules and regulations? (Note: Not applicable to most businesses) No Yes N/A If not in compliance above, is (are) the source(s) on a “schedule for compliance” with all applicable emission limitations and standards? No Yes

8. By signing, I hereby authorize the Butte County Air Quality Management District (District) to begin processing this application. I agree to pay any and all fees required by District Rules for receiving, processing and evaluating this application and for the issuance of any Permit to Operate or Authority to Construct, including District costs incurred if the project is terminated or abandoned, or the permit is denied. I agree to provide written notification within 24 hours of construction completion and/or commencement of the permitted activity. By signing, I further agree to indemnify, defend and hold the District harmless and free and clear from and against any liability, debt, obligation, claim, judgment, action, cause of action or cost or expense, of any amount and nature whatsoever, incurred by or imposed upon District as a result of, related to or in any way in connection with the District’s issuance of this permit or with any activity of the District related to this permit, all pursuant to District Rule 500, section 5.

Name of Contractor (Print): Title: _

Signature: Date:

And/or, Name of Responsible Official (Print): Title:

Signature: Date:

http://bcaqmd.org/forms-applications/stationary-sources/�

Invoice

INVOICE DATE 4/1/2018

DATE

4/1/2018

INVOICE #

14661

INVOICE # 14661

BILL TO

Beale Air Force Base Michael Mitchener-9 CES/CEIE 6425 B Street, Bldg 25390 Beale AFB, CA 95903-1708

Beale Air Force Base Michael Mitchener-9 CES/CEIE 6425 B Street, Bldg 25390 Beale AFB, CA 95903-1708

Butte Co. Air Quality Mgmt. Dist.

629 Entler Avenue, Ste 15 Chico, CA 95928-7424

TERMS

Net 60 days

DUE DATE

5/31/2018

PERMIT PERIOD

5/1-4/30

Total

Total

PAYMENT COUPON

Please detach coupon and return with your payment

Please make payments to BCAQMD. If you have any questions, please call (530) 332-9400 ext 109.

PAY YOUR INVOICE BY CREDIT/DEBIT CARD OR ELECTRONIC CHECK. Call 1-800-487-4567 or visit www.officialpayments.com. Use Jurisdiction code 1597. You will need your invoice number, payment type and to pay the exact dollar amount of your invoice.

ITEM PMT TYPE: DESCRIPTION QTYLOCATION RATE AMOUNT

ICE PERMIT TO OPERATE: Internal Combustion Engine - Diesel-Fueled BEA-96-01

12700 Oro Dam Blvd West 249.50 249.50

A 25% late charge will be assessed on all balances remaining after 15 days past the due date.

An additional 25% late fee will be assessed on all balances remaining after 45 days past due date. $249.50

$249.50