clean air act subcommittee state co-chair - booker pullen military co-chair – clifton game

Clean Air Act Subcommittee

State Co-Chair - Booker Pullen

Military Co-Chair – Clifton Game

Subcommittee Mission

• The Clean Air Act Subcommittee will exchange information in regard to Clean Air Act issues and compliance activities on military bases in North Carolina. In addition the Subcommittee will collectively identify issues of common interest and work with the State to achieve mutually beneficial agreements on air quality subjects.

Last Meeting

• Time: 10 - 1200

• Date: 6 October 2004

• Location: Parker Lincoln Building,

• Raleigh

Meeting Purpose

• (1) committee chair to report on Committee activities since the last meeting;

• (2) to allow each military member to present on topics of interest;

• (3) to allow the State members to present on pertinent regulatory topics; and

• (4) to develop goals, plans and objectives as appropriate.

Title V Permit Implementation

• Mission

• Accomplished !

Particulates from Fugitive Dust Emission Sources, 15A NCAC 2D.0544

Fugitive dust emissions are particulate emissions into the outdoor atmosphere by means other than chimneys, stacks, or vents.

Examples include haul roads, unpaved parking lots, storage piles, conveyers, and building windows and seams.

Particulates from Fugitive Dust Emission Sources, 15A NCAC 2D.0544

10% Maximum OpacityBest Management

Management PlanList SourcesOpacity MonitoringDescribe Dust Control

MeasuresSet Implementation Schedule

Exclusions - public roads, construction, timber harvesting, and production of crops

What about military operations?

Fugitive Dust

• The initial draft rule did not

exclude operations such as training exercises occurring on base

ranges.

Fugitive DustAction by the Committee

• Emily Sylvester, Camp Lejeune, discussed her concerns with military members.

• Military members and State members met for discussion.

• Finding: The State did not intend to regulate training on military bases. The current version of the rule exempts military base operations .

NESHAP UPDATEThree Major Surface Coating Rules Affecting DoD

• Aerospace NESHAP (1998)

• Ship NESHAP (1995)

• Defense Land Systems and Miscellaneous Equipment (DLSME) NESHAP

Defense Land Systems and Miscellaneous Equipment (DLSME)

Every type of coating will be regulated. If you can imagine it, and it’s coated on a military base, it will be regulated under DLSME.

DLSME(Tentative Timeline)

• 2004 DoD Submits Voluntary Data• 2005 Develop MACT Floor• 2006 Propose rule• 2007 Promulgate a final rule • 2010 Final compliance

DLSMEProbable exemptions

– Aerosol

– Facility Maintenance

– Architectural

– Adhesives

– Sealants

– Low Usage Coatings

DLSMEKey Concepts

– Existing Aerospace facility: what is an Aerospace Part?

– Existing Ship facility What is a ship part?

– Area Sources

– May be included in DLSME

– Area/Major source requirements could differ.