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Clean Air Act Subcommittee

Clean Air Act Subcommittee. State Co-Chair - Booker Pullen Military Co-Chair – Clifton Game. Subcommittee Mission.

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Clean Air Act Subcommittee

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  1. Clean Air Act Subcommittee State Co-Chair - Booker Pullen Military Co-Chair – Clifton Game

  2. 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.

  3. Last Meeting • Time: 10 - 1200 • Date: 6 October 2004 • Location: Parker Lincoln Building, • Raleigh

  4. 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.

  5. Title V Permit Implementation • Mission • Accomplished !

  6. 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.

  7. Particulates from Fugitive Dust Emission Sources, 15A NCAC 2D.0544 • 10% Maximum Opacity • Best Management Management Plan • List Sources • Opacity Monitoring • Describe Dust Control Measures • Set Implementation Schedule • Exclusions - public roads, construction, timber harvesting, and production of crops • What about military operations?

  8. Fugitive Dust • The initial draft rule did not exclude operations such as training exercises occurring on base ranges.

  9. 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 .

  10. NESHAP UPDATEThree Major Surface Coating Rules Affecting DoD • Aerospace NESHAP (1998) • Ship NESHAP (1995) • Defense Land Systems and Miscellaneous Equipment (DLSME) NESHAP

  11. 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.

  12. DLSME(Tentative Timeline) • 2004 DoD Submits Voluntary Data • 2005 Develop MACT Floor • 2006 Propose rule • 2007 Promulgate a final rule • 2010 Final compliance

  13. Aerosol Facility Maintenance Architectural Adhesives Sealants Low Usage Coatings DLSMEProbable exemptions

  14. 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. DLSMEKey Concepts

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