AIR QUALITY MANAGEMENT

USING

POLLUTION PREVENTION:

A JOINT SERVICE APPROACH

Distribution authorized to Federal Agencies only; Administrative/Operational Use; March 1998.

TABLE OF CONTENTS

DISCLAIMER

ACKNOWLEDGEMENTS

FORWARD

POLLUTION PREVENTION AND AIR QUALITY MANAGEMENT

PURPOSE

WHAT IS POLLUTION PREVENTION?

REGULATORY FRAMEWORK

EPCRA

CAA

RCRA

WHY INCORPORATE P2 INTO AIR PROGRAMS?

CROSS REFERENCES

PROCESSES

1. CLEANING AND DEGREASING

1.1 Methylene Chloride Degreasing

1.2 1,1,1-Trichloroethane Degreasing

1.3 CFC-113

1.4 Parts Washing: Stoddard Solvent

1.5 General Cleaning

1.6 Weapons Cleaning: Wipe Cleaning

1.7 Weapons Cleaning: Dip Tanks

1.8 Electronics Cleaning

2. DEPAINTING

2.1 Paint Stripping: Methylene Chloride

2.2 Research and Development

3. SURFACE COATING

3.1 Paint Gun Washers

3.2 Primers

3.3 CARC Painting

3.4 Touch-Up Painting

3.5 General Painting

3.6 Architectural Coatings

3.7 Cadmium Plating

3.8 Chromic Acid Anodizing

3.9 Chromate Conversion Coating

3.10 Hard Chrome Plating

3.11 Coating Technology

4. COMBUSTION

4.1 Medical Waste Incinerators

4.2 Classified Waste Incinerators

4.3 Municipal Waste Combustors

4.4 Treatment, Storage, Disposal Facility

4.5 Boilers

4.6 Vehicles

4.7 Aerospace Ground Equipment

4.8 Generators

4.9 Jet Engine Testing

5. STORAGE

5.1 Listed Substance Storage

6. TRAINING

6.1 Fire Fighting Training

6.2 Field Training Exercises

6.3 Weapons Training at Firing Ranges

7. MISCELLANEOUS

7.1 Ethylene Oxide Sterilizing

7.2 Fuel Dispensing

7.3 Pesticides

7.4 Lubricants

7.5 Adhesives and Sealants

7.6 Potential to Emit

APPENDICES

Appendix A: ACRONYMS

Appendix B: APPROVAL AUTHORITY

Specifications and Standards: Obtaining Approval for Change

Specifications and Standards: Integrating P2 into Acquisition

How to Recommend an Air Force Tech Order (TO) Change

How to Recommend a Military Specification (MILSPEC) Change

Appendix C: WEB SITES

Appendix D: REGULATORY INFORMATION

Clean Air Act And Toxic Release Inventory Reporting Requirements

Governing Department Of Defense and Service

Regulations for Pollution Prevention

Initiatives to Reauthorize The PPA

Appendix E: EPA PROGRAMS & RESOURCES

Significant New Alternatives Policy Program (SNAP)

Design for the Environment

EPA Publications

Appendix F: DoD P2 SERVICES

Joint Service Pollution Prevention Technical Library

The HAP Status Binder

The Air Force Environment, Safety, and Occupational Health (ESOH)

Air Force Environmental Helpline

Navy Pollution Prevention Equipment Program

Navy Fleet Assistance Support and Technology Transfer (FASTT)

Army Pollution Prevention Investment Fund (P2IF)

Army Environmental Helpline

Joint Group on Acquistion Pollution Prevention (JG-APP)

Appendix G: HOW TO INCORPORATE P2

DISCLAIMER

This information resource is not a DoD Policy document. This document primarily contains ideas and information about what others in the DoD are doing. All decisions to implement any of the opportunities described herein should be authorized through normal channels.

The mention of product names in this document does not constitute endorsement by the Services, DoD, or other Federal agency, but is for clarification purposes only.

ACKNOWLEDGEMENTS

The development of this document was sponsored by the U.S. Army Environmental Center. The Center supports implementation of the Army compliance program and encourages the use of pollution prevention techniques to minimize the impacts of regulatory requirements. More information about the Army Air Quality Compliance Program can be found by visiting the USAEC website at http://aec-www.apgea.army.mil or calling the Air Quality Media Manager at
(410) 671-1214/DSN 584.

The authors gratefully acknowledge the substantial contributions of the installations, as well as the National Aeronautics and Space Administration and the U.S. Coast Guard.

FORWARD

This Joint document was created through the efforts of the U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM), the U.S. Air Human Systems Center (HSC/OEBQ) and the Naval Facilities Engineering Service Center (NFESC). These three organizations have gathered information from installations within the Services, NASA, Coast Guard and from other resources to assemble within this document. This document highlights pollution prevention (P2) techniques that have either been successfully implemented at facilities or have potential to be implemented successfully. The current status of some relevant research efforts are included where appropriate. This document is not comprehensive. There was no data call, and many valuable ideas may have been missed. It is our intent to update this document as our readers bring new information to our attention. This document is a clearinghouse of potential solutions to Air Compliance Programs using P2, and will be posted on the Defense Environmental Network Information eXchange (DENIX) website.

Contact Information:

Army & others:

USACHPPM
Air Programs: (410) 671-3500/DSN 584
Linda Jekel
#CHPPM_Pgm42@chppm-ccmail.apgea.army.mil

Navy/Marine Corps:

NFESC
Compliance Branch: (805) 982-3567/DSN 551
Lisa Trembly
Ltrembl@nfesc.navy.mil

Air Force:

HSC/OEBQ

Human Systems Center: (210) 536-3305/DSN 240
Captain Kyle Blasch
Kyle.Blasch@guardian.brooks.af.mil

POLLUTION PREVENTION AND AIR QUALITY MANAGEMENT

PURPOSE

This document is for Air Quality Managers who would like to learn more about their options for using pollution prevention (P2) to manage air quality and achieve compliance. This is a forum for you to learn from each other about what works and what doesn't work. Success stories from throughout the Services are the core of this document. In addition, background information and summaries of current research are included for some processes. All of this information in the body of the document is organized according to the affected process, with references to associated regulations. The appendices also contain a variety of useful information.

This document differs from and compliments the Joint Service P2 Technical Library and the Hazardous Air Pollutant (HAP) Status Binder. The Joint Service P2 Technical Library was created to outline "off the shelf" technologies for use by DoD installations. The HAP Status Binder was developed to keep DoD Air Quality Managers apprised of the status of National Emission Standards for Hazardous Air Pollutants (NESHAPs). So while the former is oriented toward what technologies are available, and the latter is oriented toward what the regulations require, this document presents what is actually being done now in the Military and provides contact information to enhance networking. Web addresses are listed in Appendix C.

WHAT IS POLLUTION PREVENTION?

P2 means changing products used or manufacturing processes to reduce impact to the environment. This involves incorporating environmental considerations into product design and into the design, operation, and maintenance of production processes resulting in improved efficiency and performance. By operating more efficiently we protect human health, strengthen our economic well-being, and preserve the environment. P2 is a cost-effective and sound approach to environmental protection and is key to obtaining environmentally sustainable economic development.

Executive Order 12856, signed by President Clinton in August 1993, required Federal facilities to comply with the Emergency Planning and Community Right to Know Act (EPCRA), which was authorized in October 1986, and the Pollution Prevention Act (PPA) which was authorized in December 1990. The DoD required every facility that was not scheduled for operational closure by 31 December 1997 to develop and implement a P2 plan. This plan is supposed to address the actions required by the facility for reducing pollution from all sources and to all media, including the installation’s strategy for meeting the goal of a 50% reduction by 1999 in Toxic Release Inventory reportable releases and off-site transfers.

DoD Directive 4715.1 defined P2 as source reduction (as defined in the PPA of 1990, 42 U.S.C. Sections 13101-13109) and other practices that reduce or eliminate the creation of pollutants through: (a) increased efficiency in the use of raw materials, energy, water, or other resources; or (b) protection of natural resources by conservation.

The PPA defined source reduction as "any practice that (a) reduces the amount of any hazardous substance, pollutant, or contaminant entering any waste stream or otherwise released into the environment (including fugitive emissions) prior to recycling, treatment, and disposal; and (b) reduces the hazards to public health and the environment associated with the release of such substances, pollutants, or contaminants. The term includes equipment or technology modification, process or procedure modification, reformulation or redesign of products, substitution of raw materials, and improvements in housekeeping, maintenance, training, or inventory control." Source reduction does not entail any form of waste management (e.g., recycling and treatment).

Under Section 6602(b) of the PPA, Congress established a national policy that:

• pollution should be prevented or reduced at the source whenever feasible;
• pollution that cannot be prevented should be recycled in an environmentally safe manner whenever feasible;
• pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and
• disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner.

The primary focus of Air Quality Managers is to comply with regulations. Pollution prevention is a tool to meet or proactively surpass the regulatory requirements.

REGULATORY FRAMEWORK

EPCRA

The Emergency Planning and Community Right-to-Know Act (EPCRA) was promulgated as Title III of the Superfund Amendments and Reauthorization Act in 1986. The EPCRA requires covered facilities to:

1. Follow certain procedures in the event of a dangerous accidental release.
2. Conduct inventories of hazardous materials at the facility and make this information available to the local community.
3. Conduct a Toxic Release Inventory (TRI) each year and report to the EPA and the State the quantities of toxic chemicals released to the environment.

Federal facilities were not covered by EPCRA, but Executive Order 12856 directed Federal agencies to comply with EPCRA and to reduce their reportable releases and off-site transfers of toxic chemicals by 50% by 31 December 1999 using the 1994 TRI reports as the baseline.

In the DoD’s 1994 TRI report, air emissions represented about two-thirds of all TRI reportable releases and off-site transfers (see Figure 1), and over 97% of all TRI reportable on-site releases (see Figure 2). The DoD did not realize the high percentage of toxic releases to the air until the release of the 1994 TRI report. These air emissions are primarily from maintenance activities associated with the painting and depainting of aircraft and cleaning and degreasing activities. The list of hazardous air pollutants (HAPs) included in the 1990 amendments of the Clean Air Act (CAA90) was based to a large extent on the TRI list. Title III of the CAA90 was one of the Environmental

Figure 1: TRI Reportable Releases And Off-Site Transfers for 1994 and 1995

Protection Agency's (EPA’s) tools to achieve a reduction of TRI pollutants. Table 1 compares the TRI top ten chemicals reported for the DoD for 1994 and 1995. Notice that all but one are HAPs.

Figure 2: 1994 DoD TRI On-Site Releases By Media

Table 1: Change in Top 10 Chemical Releases and Transfers Information

CAA

The primary goal of the Clean Air Act (CAA) is to "protect the public" from air pollution with an "adequate margin of safety". End-of-pipe control technologies have been the primary method of reducing pollution emissions.

Under CAA Title I Section (§)112 and §129, Congress mandates that stationary sources be required to use Maximum Achievable Control Technology (MACT) or Generally Achievable Control Technology (GACT). Title I requires the EPA to set National Ambient Air Quality Standards (NAAQS) and State and Local agencies have the option to use either tools developed by the EPA or within their own agencies to control air emissions from stationary sources. New Source Performance Standards, Control Techniques Guidelines, Alternative Control Techniques, Best Available Control Technology, Best Available Control Measures, and Reasonably Available Control Technology are examples of some of the methods State and Local agencies typically use to control emissions. The strong emphasis on controlling emissions using control technologies under the CAA is easy to see. Facilities generally find it much easier to install a standard control technology called out under a specific regulation than to identify and implement a P2 option.

In recent years, EPA has been writing P2 opportunities along with control technologies into their standards. The EPA has tried to change their focus to performance based and cost effective standards.

Developing P2 strategies may require longer term investing than the three years usually allotted for compliance with a standard. Some processes may require large equipment changes thus making P2 cost prohibitive under the current funding system, which does not accommodate longer payback periods. This encourages the use of control technologies in those cases where the upfront cost is lower. The EPA has been trying to write into rules incentives for industry to develop P2 by giving longer time periods to comply if P2 initiatives are implemented (a one year extension is the typical length of the time period). The EPA also seeks to provide regulatory relief for the development of P2 through such cross media efforts as the Common Sense Initiative, Project XL, and ENVVEST. All of these programs have been very difficult to implement within both Industry and the DoD because consensus on solutions among industry, the EPA, and environmental groups has proved difficult to achieve.

The P2 initiatives that have been the most successful are those with a low up-front cost, such as coating and degreasing processes. Coating reformulations and application techniques have significantly contributed to HAP and volatile organic compound (VOC) reductions. Switching to aqueous degreasers has reduced both VOCs and operating costs.

RCRA

The Solid Waste Disposal Act (SWDA) of 1965 was the first Federal legislation that addressed the nation's waste management practices. This act, as amended by the Resource Conservation and Recovery Act (RCRA) of 1976 and the Hazardous and Solid Waste Amendments (HSWA) of 1984, is commonly referred to as RCRA.

Within the DoD, P2 seems to focus on the minimization of hazardous and solid wastes. There are four possible reasons for this. (1) The Resource Conservation and Recovery Act (RCRA) is the environmental law for which the DoD has paid the most fines. In addition, a number of DoD employees have been prosecuted for violation of RCRA regulations. Reducing the use of hazardous materials reduces liability. (2) There are hazardous waste minimization requirements within RCRA. Hazardous waste generators must submit a Biennial Report, to include a description of the efforts undertaken and progress made to reduce the volume and toxicity of waste generated [40 CFR 262.41(a)(6,7)]. In addition, RCRA requires the permit holder of a treatment, storage, and disposal facility to have, at a minimum, annual certification that there is a program in place to reduce the volume and toxicity of the hazardous waste generated, and to minimize the present and future threat to human health and the environment [40 CFR 264.73 (b)(9)]. (3) Hazardous waste disposal costs are high, so that P2 in this area yields a direct and immediate cost savings. (4) Solid and hazardous waste quantities and costs are more easily determined than air emission quantities and costs.

Many Military documents focus on solid and hazardous waste P2. The Joint Service P2 Technical Library’s introduction states that the purpose of the Library is "to identify available P2 technologies, management practices, and process changes that will reduce the amount of hazardous and solid waste being generated at joint service industrial facilities."

Some P2 initiated because of RCRA has benefited air quality, despite the apparent trend to pigeonhole P2 with hazardous/solid waste minimization efforts. Examples of common P2 applications which were initiated because of hazardous waste but have benefited air quality are: vapor degreasers replaced with aqueous parts washers, low VOC coatings formulated, and parts depainted using blasting techniques such as plastic, glass, wheat starch, or sodium bicarbonate where once solvents were used.

WHY INCORPORATE P2 INTO AIR PROGRAMS?

P2 is typically managed by the Hazardous Waste Manager or the P2 Program Manager. Consequently the installation’s Air Program is not usually involved with P2 and opportunities may be missed. Yet there are often substantial benefits from incorporating P2 into Air Programs:

1. Immediate Cost Savings

• Costs. P2 can be more economical and many applications make good business sense. Material and process costs may be reduced.
• Fees. Annual permit fees can be reduced since fees are usually proportional to emission rates.
• Disposal costs. Disposal costs of hazardous by-products are often eliminated.

2. Regulatory Relief

• Liability. P2 yields reduced liability for commanders.
• Safety. P2 results in reduced health hazards for airmen, marines, sailors, soldiers, and civilians.
• Permitting. It may be possible in some cases to eliminate the need to be permitted, depending on Federal/State/Local requirements.
• Emission Reduction Credits. Voluntary emission reductions can be converted into Emission Reduction Credits (ERC's). ERC's can then be used for base growth. Usually New Source Review trading provisions allow for interpollutant trading (i.e., NO_x emissions can be traded for a new VOC source since both pollutants contribute to smog). Offset provisions need to be considered, however, when exercising these programs. In the South Coast Air Quality Management District in Los Angeles, CA, emissions trading occurs under the Regional Clean Air Incentives Market (RECLAIM). Under RECLAIM, if a facility reduces the amount of emissions it is allocated before the compliance date, these emissions can be banked or traded for use by other facilities or in the future, creating a very robust emissions trading market. Also, in the FY98 DoD Authorization Bill, new ERC provisions authorized the Secretary of Defense to write regulations allowing the retention of proceeds to a cap of $500k DoD wide. The CAA Services Steering Committee is in the process of developing guidance to find the best way for installations to retain proceeds that previously were required to be deposited to the U.S. Treasury.
• Conformity Analysis. The CAA requires a Federal agency to demonstrate that a new Federal action will not cause deterioration of air quality or impact attainment status in a nonattainment or maintenance area in accordance with the State Implementation Plan (SIP). Military installations/units, functions, or weapons systems realignment occurring as a result of Base Realignment and Closure (BRAC) are required to comply with conformity. For example, a facility that is gaining aircraft and is located in a nonattainment area will have to offset the addition of emissions from the added equipment. If a facility can show that because of P2 projects (or otherwise) they have reduced emissions, the facility may then have sufficient emission offsets required to allow the introduction of the additional equipment. Therefore, a facility will have more growth potential if P2 is employed. Conversely, if the emission offsets are not available to meet the requirements of the SIP, the facility may not be able to increase operations.
• National Ambient Air Quality Standards (NAAQS) are tightening. Therefore emission offsets for conformity analysis and New Source Review will be increasingly more difficult to obtain.
• Regulatory Incentives. Even though CAA regulations are "control" oriented, efforts by EPA have been made to put incentives on P2 strategies in Air Quality Programs.
• §112(r) Relief. A number of installations are reducing the amount of chlorine associated with water treatment processes. If the process no longer exceeds the threshold of a substance regulated under the Accidental Release Provisions of §112(r) (40 CFR 68), it will not be a covered process, and will not necessitate a Risk Management Program and Plan.
• Compliance deadlines. Compliance extensions can be granted when using P2 in lieu of controls for the more recently developed regulations.
• Recordkeeping. Monitoring, recordkeeping, and reporting can be substantially reduced or eliminated.
• Enforcement Agreements. EPA is developing a program through the Office of Enforcement and Compliance Assurance called "Identification of P2 Technologies for Possible Inclusion in Enforcement Agreements Using Supplemental Environmental Projects and Injunctive Relief". This program requires P2 during enforcement for those facilities/industries out of compliance for appropriate targeted sectors.
• Risk Assessment. California’s Air Toxic "Hot Spots" Information and Assessment Act (Assembly Bill 2588) regulates HAP emissions based on risk. Facilities are required to inventory their hazardous emissions and conduct a Health Risk Assessment. This regulation has provided a powerful incentive for P2 as facilities are required to notify the public of the health risks imposed by the facility. Facilities are required to reduce their risks to the community to acceptable levels. CAA §112(f) Residual Risk program will be implemented by EPA in the near future and could have a similar impact nationally as Assembly Bill 2588 has had in California.

3. Regulatory Policy Compliance

• P2 Plans. P2 plans which address all media are required for all bases/installations.
• TRI. Installations that meet the threshold for TRI reporting must have a strategy to reduce toxic chemical releases and off-site transfers by 50% by December 1999. P2 will help meet the 50% reduction.
• Multi-media compliance. Some chemicals are regulated under multiple laws, such as CAA, CERCLA, CWA, OSHA, and/or the RCRA. From a multimedia regulatory framework, it makes more sense to substantially reduce or eliminate the use of such chemicals rather than trying to marshall resources to comply with the increasingly stringent regulations. For example, OSHA published standards governing methylene chloride that went into effect 10 April 1997. OSHA reduced the 8 hour time weighted average (TWA) from 500 ppm to 25 ppm. OSHA also reduced the existing short-term exposure limit from 2,000 ppm to 125 ppm, measured as a 15 minute TWA. An action level is now set at 12.5 ppm measured as an 8 hour TWA. What this means is that working with methylene chloride is becoming more and more difficult, and end of stack controls to meet the requirements of the CAA (outside) will not help facilities to meet the provisions of OSHA (inside). However, a P2 alternative to methylene chloride would satisfy regulations under all the laws. Recently the OSHA limits were also tightened for the use of methyl ethyl ketone which is also strictly regulated by the CAA and RCRA.
• Safety. In some unusual circumstances, air pollution control devices have been associated with fire or explosions. Although these phenomena are uncommon, facilities would nevertheless decrease the risks of such occurrences. The EPA extended the deadline for compliance with the Ethylene Oxide Sterilizers NESHAP because of reports of explosions at ethylene oxide sterilization facilities. Investigations at the sterilization facilities have not concluded that the explosions were caused by the air pollution control equipment, however, the EPA is recommending controls not be used until their investigation is completed. Additionally the EPA's Chemical Emergency Preparedness and Prevention Office (CEPPO) in May 1997 issued a warning about fire hazards associated with activated carbon systems if proper procedures are not followed.
• Greenhouse Gases. Combustion sources may be further regulated to meet the provisions of international agreements on greenhouse gases.

CROSS REFERENCES

The following tables cross-reference statutes, regulations, and executive orders to processes and sources. Success stories and potential alternatives gathered from Department of Defense installations are found under the Processes section. Points of contact and sources of the information are listed for further questions.

Table 2

Table 3

Table 4

Table 5