Good air quality contributes to Army readiness and quality of life by providing direct health and economic benefits to soldiers and civilians. A commander’s influence and guidance may resolve issues that could impair readiness. Commanders have occasionally had to participate in negotiations with regulators so that training could continue. In addition, the commander’s authority may help overcome citizens’ and regulators’ concerns about air pollution from Army activities.

Examples of Sources of Air Pollution Emissions at Installations

• Boilers that produce heat and steam.
• Fueling operations, especially gasoline fueling.
• Graphic arts.
• Degreasing operations.
• Vehicle and building painting operations.
• Training activities, especially vehicle maneuver training.
• Firing ranges.
• Waste disposal, such as incineration.
• Dry-cleaning operations.
• Emergency back-up generators.

Particulate matter regulations, more than any other Clean Air Act (CAA) regulation, have interfered with training. Enforcement of these regulations has restricted smoke/obscurant emissions. Smoke/obscurant clouds are made up of particulate matter measuring less than 2.5 micrometers in aerodynamic diameter. Because of the large volume in which they are generated, fog oil clouds can cause violations of the particulate matter standards.

Commanders can implement programs, such as pollution prevention and automated data collection systems, that will reduce their installation’s Clean Air Act compliance costs. Pollution prevention, or "P2," is the substitution of less polluting processes or materials. These new processes and materials pay for themselves by reducing material, energy, waste disposal, and environmental compliance costs.

Examples of Cost-Saving P2 Measures
Measure	Advantages
Low solvent paint	Decreases Clean Air Act compliance costs Reduces EPCRA emissions
Reduce heater usage by increasing building and heater insulation and/or purchasing solar water heaters	Decrease energy costs Reduce boiler pollutant emissions Reduce CAA compliance costs
Stage I and II vapor control on gasoline dispensers	Reduces gasoline vapor emissions Large source of hazardous air pollutant emissions
Aqueous parts washers	Reduce halogenated parts cleaner costs Reduce CAA compliance costs Reduce EPCRA emissions
Sputtering or vapor deposition metal plating	Reduces chromium emissions to air and water Reduces hazardous waste disposal costs
Your environmental office should have a list of P2 opportunities specific to your installation.

The Clean Air Act requires installations to control, manage, reduce and track the volume of their air emissions. Improved data management can reduce both compliance costs and environmental fines assessed against your installation. Inadequate data collection accounts for most CAA Notices of Violation.

It isn’t necessary to spend tens of thousands of dollars to collect data required by the Clean Air Act. Implementation of the Hazardous Substance Management System (HSMS) is a cost-effective way to improve data-gathering. HSMS, a "cradle to grave" automated tracking system sponsored by DESCIM, is the DoD standard for tracking hazardous materials requisitioned, received, stored, issued, used, recycled, and hazardous waste disposed. It also maintains information on all processes that use hazardous materials or generate hazardous waste, calculates chemical release information, and generates all the required federal environmental reports.

The massive size and scope of the Clean Air Act Amendments of 1990 (CAAA-90) make clean air regulations among the most intrusive. The EPA and the states have only promulgated about half of the regulations required by these amendments.

The CAAA-90 legislation targets many operations on Army facilities. Consequently, the Army faces significant increases in the cost of doing business. Major installation impacts come from Titles I (Attainment), III (Hazardous Air Pollutants), V (Permits), VI (Stratospheric Ozone Protection) and VII (Enforcement).

Title I requires the EPA to write regulations bringing all ambient air into compliance with the National Ambient Air Quality Standards (NAAQS). These standards set the maximum allowable concentrations of ground-level ozone, carbon monoxide, sulfur dioxide, nitrogen oxides, inhalable particulate matter, and lead. It establishes a set of emissions control standards for areas of the country meeting the NAAQS, and other sets for areas failing to meet these standards. Most of Title I is directed at controlling pollutant emissions which contribute to ground-level ozone formation.

Army Impacts of Title I

• Military sources of volatile organic compounds (VOCs) typically affected by Title I include boilers, fuel storage and dispensing facilities, spray painting and coating lines, organic solvent degreasing operations, and dry cleaners.
• Affected military nitrogen oxide (NOx) sources include combustion processes, such as open burning/open detonation (OB/OD) sites, engine test cells, various waste incinerators, and fossil-fuel-fired steam/hot water boilers.
• Military inhalable particulate sources include smoke/obscurant training, boilers, OB/OD, and maneuver training.
• Major requirements include:
  • Controls on boiler emissions.
  • Use of low-solvent chemical agent resistant coating.
  • Restrictions on maneuver and smoke/obscurant training.
• New operations in non-attainment areas must demonstrate that they will not have a negative impact on the goals or purpose of the state implementation plan.

Title III requires the EPA to write regulations reducing emissions of hazardous air pollutants (HAPs) to the nation’s air. Between November 1992 and November 2000, the EPA will write HAP control regulations for 175 classes of industrial activities, 30 of which are found on at least one Army installation. This title also establishes contingency planning for accidental releases of hazardous substances.

Army Impacts of Title III

• Affected HAP sources must modify processes or install control equipment to limit emissions and comply with maximum available control technology (MACT).
• Title III requirements impact most of the VOC sources listed under Title I.
• Emission levels have to be verified in a manner acceptable to regulators and quantified by either continuous emission monitoring, stack sampling, or estimation using EPA-approved emission factors.

Under Title V, each installation meeting the EPA’s definition of a major source must obtain a single permit covering all its regulated air emissions sources. Other than laboratories and administrative posts, most Army installations meet this definition.

The Title V permit must include the following information:

• Results of a regulatory review that includes all federal, state and local air emissions regulations, and a list of those that apply to the installation.
• A list of all regulated sources.
• A list showing the requirements of all regulations applying to these sources.
• A Compliance Plan describing how the installation will achieve and maintain compliance with all applicable air emissions regulations.
• A Monitoring Plan describing the monitoring and record-keeping through which the installation will verify compliance with all applicable regulations.

These permits have to be "federally enforceable." This means that the permit requirements can be enforced by the EPA, state regulatory agencies, or private citizens. An Army installation violating a federally enforceable requirement is more likely to be caught and cited than if it were to violate a state enforceable requirement.

Army Impacts of Title V

• Army installations must pay annual permit fees based on the level of air pollutants permitted.
• Data collection required under Title V permits consumes more of an installation staff’s time than any other Clean Air Act regulation.
• Failure to comply with any aspect of the Compliance Plan or permit can be grounds for enforcement action.

Title VI bans the production of all ozone-depleting substances (ODS) after 2001, including chlorofluorocarbons (CFCs), halons and other halogenated solvents. It also requires training for the technicians who work on machines that capture and recycle ozone-depleting chemicals (ODCs) from systems that use ODCs.

Army Impacts of Title VI

• Army installations eventually will have to replace systems, such as air conditioners, chillers, fire suppression systems, and precision metal parts cleaning, that use these chemicals.
• The Army operates a few systems, such as armored vehicle fire suppression systems, using ozone-depleting chemicals for which there are no suitable replacements.
• The Army Acquisition Pollution Prevention Support Office (AAPPSO) is responsible for supplying essential systems with ozone-depleting chemicals.

Title VII describes civil and criminal penalties for violations of air pollution control requirements. Some violations that were previously misdemeanors are now felonies, with liability targeted at senior management rather than operators. Enforcement actions include high maximum fines and prison terms.

Army Impacts of Title VII

• Failure to comply with either administrative or substantive air quality requirements may be costly. The EPA may write "traffic tickets" assessing penalties of up to $5,000 per violation during a routine inspection.
• Administrative violations such as inaccurate or out-of-date permit data are also grounds for enforcement action.
• Enforcement efforts are specifically directed at management to compel regulated entities to plan ahead and allocate appropriate resources.
• Lack of "hands on" involvement is no longer a valid defense for a violation.To a lesser extent, Titles II (Mobile Sources) and IV (Acid Rain) of the Clean Air Act also may affect Army operations.

Title II regulates pollutant emissions from non-tactical vehicle engines. Title II:

Sets pollutant limits for motor vehicle exhaust emissions.Requires manufacturers to investigate feasibility of onboard canisters to control refueling emissions.Compels automobile manufacturers to limit carbon monoxide, hydrocarbon, and NOx emissions by improving design standards.

Requires reformulated and oxygenated gasoline in cities with the worst ozone and carbon monoxide non-attainment.

In non-attainment areas, requires that a percentage of each non-tactical vehicle fleet (such as GSA motor pools) be clean-fuel vehicles.

Army Impacts of Title II

• As of the 1998 model year, Army installations in affected non-attainment areas must begin to procure and use clean-fuel vehicles. Clean alternative fuels include methanol, ethanol, reformulated gasoline, natural gas, liquefied petroleum gas and electricity.
• Non-tactical fleet vehicles used in non-attainment areas must be included in Inspection and Maintenance (I & M) programs. Such programs generally have an annual inspection requirement which can be enforced through denial of vehicle registrations.
• Army installations also may be required to implement a program to verify I&M participation for employees’ privately owned vehicles.

Title IV primarily affects large electric utility companies with sulfur dioxide emissions, which are considered to be a major sources of acid rain precursors.

Army Impacts of Title IV

• Because acid rain is a major environmental issue in the United States, Canada and several other regions around the world, it is an environmental security issue.
• Acidification of lakes, destruction of forests, and increased weathering of exposed materials are some of the direct effects of these pollutants on Army installations. These can influence an installation’s training lands, conservation programs and overall readiness.
• Electricity costs also may increase gradually over the next two decades.

State agencies have a major role in managing air quality programs. State regulations applicable to installation activities are often more detailed and encompassing than federal regulations. Facets of state involvement in air pollution management include development of State Implementation Plans (SIPs), permitting of stationary sources, air toxins emissions regulations, and vehicle I & M programs.

• Identify, inventory and monitor air pollutant emissions and ambient air quality.
• Reduce pollutants to regulatory levels to protect health and reduce permit costs.
• Implement HSMS.
• Procure control equipment that meets regulatory standards.
• Ensure design and operation of military equipment are in accordance with regulations.

• Verify, identify, monitor, and maintain an up-to-date inventory of emission sources.
• Obtain permits and provide reports for emission sources as required by regulations.
• Participate in the air pollution regulatory development process.
• Implement low-cost pollution prevention systems, and discourage institutional resistance to change.
• Maintain programs to train air emissions management personnel.
• Conduct motor vehicle I&M to ensure regulatory compliance.
• Implement pollution prevention measures that reduce environmental compliance costs.
• Ensure that Department of Logistics and Department of Public Works personnel collect material-use data required by the Title V permit.
• Confirm that installation environmental staff know state air-quality and emissions regulations.
• Notify their MACOM immediately whenever a Notice of Violation (NOV) is received.

AR 200-1, "Environmental Protection and Enhancement," February 1997.
AR 420-49, "Facilities Engineering Utilities Services Guide," April 1997.
DoD Directive 6050.9, "Chlorofluorocarbons (CFCs) and Halons," February 1989.
The Clean Air Act regulations are presented in Title 40 CFR, Parts 50-87.
AR 40-5, "Preventive Medicine," August 1986.
USAEHA Report, "Summary of the Clean Air Act Amendments of 1990," Titles I, II, III, V, VI, and VII, April 1991.