Possible Impact of Pending National Emission Standards for Hazardous Air Pollutants

1. Possible Impact of Pending National Emission Standards for Hazardous Air Pollutants Steve Finley, CTC HQ AFMC/LGPE DSN 787-8090

2. OVERVIEW Current NESHAPs DoD concerns Defense Land Systems and Miscellaneous Equipment NESHAP Implementation of new rule Military MACT Surface Coating NESHAP Military MACT Surface Coating NESHAP

3. Current NESHAPS The promulgation of the Aerospace NESHAP under the Clean Air Act, has been generating several other NESHAPs to address surface coating of various source categories. Two examples of surface coating rules include MMPP and PPP NESHAPS. A major concern was identified by DoD and conveyed to the EPA with regards to complying with so many different surface coating rules, many of which could affect a single installation. These rulings have different requirements, contain different units for HAP emissions and would have made record keeping extremely burdensome. As a result, it was proposed that DoD opt out of all surface coating rules except for Aerospace and Shipbuilding NESHAPs. Instead DoD would help develop and comply with one rule now known as the Defense Land Systems and Miscellaneous Equipment (DSLME). The promulgation of the Aerospace NESHAP under the Clean Air Act, has been generating several other NESHAPs to address surface coating of various source categories. Two examples of surface coating rules include MMPP and PPP NESHAPS. A major concern was identified by DoD and conveyed to the EPA with regards to complying with so many different surface coating rules, many of which could affect a single installation. These rulings have different requirements, contain different units for HAP emissions and would have made record keeping extremely burdensome. As a result, it was proposed that DoD opt out of all surface coating rules except for Aerospace and Shipbuilding NESHAPs. Instead DoD would help develop and comply with one rule now known as the Defense Land Systems and Miscellaneous Equipment (DSLME).

4. The NESHAP is also called the Military MACT (Maximum Achievable Control Technology) NESHAP Currently in the Data collection phase DoD is also trying to figure out whether it would be best for surface coating associated with facility maintenance should be covered by the NESHAP. At this point, it appears that at least the AIR Force is leaning towards �no�, since facility maintenance (e.g., painting schools, family housing, warehouses, etc.) is not a core function. Also, DoD is trying to determine the amount of surface coating that is done in facility maintenance at DoD installations. The hope is that we can convince EPA that we don�t do that much. Also, apparently, EPA may be developing a rule to cover area sources and coating operations associated with facility maintenance that are not covered under a specific HAP rule.The NESHAP is also called the Military MACT (Maximum Achievable Control Technology) NESHAP Currently in the Data collection phase DoD is also trying to figure out whether it would be best for surface coating associated with facility maintenance should be covered by the NESHAP. At this point, it appears that at least the AIR Force is leaning towards �no�, since facility maintenance (e.g., painting schools, family housing, warehouses, etc.) is not a core function. Also, DoD is trying to determine the amount of surface coating that is done in facility maintenance at DoD installations. The hope is that we can convince EPA that we don�t do that much. Also, apparently, EPA may be developing a rule to cover area sources and coating operations associated with facility maintenance that are not covered under a specific HAP rule.

5. In the can limits v. facility-wide average limits: Facility-wide average limits would be more rigorous to comply with. Whereas, in certain instances, MILSPECs can be changed to require coatings that would be compliant with the DLSME NESHAP. In the can limits v. facility-wide average limits: Facility-wide average limits would be more rigorous to comply with. Whereas, in certain instances, MILSPECs can be changed to require coatings that would be compliant with the DLSME NESHAP.

6. DoD is trying to figure out whether it would be better for the DSLME to apply to area sources as well, or if it would be better for area sources to be covered by the other surface coating rules. Disadvantage: If area sources included, then they may be subject to MACT, whereas, area source HAP rules are typically subject to GACT. Advantage: Area sources subject to one rule, whereas, if not covered by DLSME, area sources would be covered by separate rules and potentially different emission limits and compliance approaches. Also, avoids overlap of NESHAPs that apply to same activity. DoD is trying to figure out whether it would be better for the DSLME to apply to area sources as well, or if it would be better for area sources to be covered by the other surface coating rules. Disadvantage: If area sources included, then they may be subject to MACT, whereas, area source HAP rules are typically subject to GACT. Advantage: Area sources subject to one rule, whereas, if not covered by DLSME, area sources would be covered by separate rules and potentially different emission limits and compliance approaches. Also, avoids overlap of NESHAPs that apply to same activity.

7. What is going on, is that EPA is planning on regulating painting of facilities. Right now, they are just looking at production type facilities. (i.e. painting of the paint booths themselves, storage tanks, production equipment, etc.) Some industries can emit a lot of HAP from this kind of painting. We don't think that DoD facilities emit much HAP from this kind of painting. To convince EPA of this, we need to get them some data on our HAPs emissions from this painting.What is going on, is that EPA is planning on regulating painting of facilities. Right now, they are just looking at production type facilities. (i.e. painting of the paint booths themselves, storage tanks, production equipment, etc.) Some industries can emit a lot of HAP from this kind of painting. We don't think that DoD facilities emit much HAP from this kind of painting. To convince EPA of this, we need to get them some data on our HAPs emissions from this painting.

8. DoD/NASA Workgroups State rules workgroup � needs coatings expert(s) Data/data categories workgroup Coating usage workgroup Recordkeeping workgroup (interview painters) Defining systems to be regulated under DLSME vs. Aero or Ship These are working groups that have been formed to help develop this NESHAP. A request for data has been sent to MAJCOMs and ALCs to provide data on coatings used. This data is being separated by FSC and use to be used in determining some of the requirements for the DSLME These are working groups that have been formed to help develop this NESHAP. A request for data has been sent to MAJCOMs and ALCs to provide data on coatings used. This data is being separated by FSC and use to be used in determining some of the requirements for the DSLME

11. We believe that the best data available is data related to installation painting contracts. Installations contract out most of their facility painting. We believe that we installation contract data will show EPA that installations only repaint their facilities every few years. Contracts may also include estimates of the amount of paint that is required. What we would like to do is work with installation CAA POCs and their contracting offices to get data showing the frequency with which installations repaint their facilities. If you would include the information in the attached power point presentation in your DLSME presentation, I believe it would help us get the data that we need to provide EPA. Paul Josephson and Scott Cummings of Army Environment Center, can assist in dealing with contracting offices to obtain the data.We believe that the best data available is data related to installation painting contracts. Installations contract out most of their facility painting. We believe that we installation contract data will show EPA that installations only repaint their facilities every few years. Contracts may also include estimates of the amount of paint that is required. What we would like to do is work with installation CAA POCs and their contracting offices to get data showing the frequency with which installations repaint their facilities. If you would include the information in the attached power point presentation in your DLSME presentation, I believe it would help us get the data that we need to provide EPA. Paul Josephson and Scott Cummings of Army Environment Center, can assist in dealing with contracting offices to obtain the data.

12. Current Status As stated earlier this NESHAP is in the beginning phases, we must be ready when the rule is finalized and the limits/restrictions go into affect. Bottom line no new VOC HAP levels have been established as of yet so we are not sure what to gear up for. One thing is for certain Cr+6 in the coating system will be targeted with this new NESHAP. This tends to validate all the work everyone has done in this area.As stated earlier this NESHAP is in the beginning phases, we must be ready when the rule is finalized and the limits/restrictions go into affect. Bottom line no new VOC HAP levels have been established as of yet so we are not sure what to gear up for. One thing is for certain Cr+6 in the coating system will be targeted with this new NESHAP. This tends to validate all the work everyone has done in this area.

13. Timeline