Clean Air Act Compliance Support – Aberdeen Proving Ground

Clean Air Act Compliance Support – Aberdeen Proving Ground

Since 2016, Bluestone has been performing air compliance support under the CAA for APG.

The Installation has two separate Title V permits for the Aberdeen Area and Edgewood Area. To date, under contracts W56ZTN-16-F-0014 (GSA) and W56ZTN-17-D-0006 (BESS III) Delivery Order W56ZTN-18-F-0119, Bluestone has completed over $615,000 in CAA compliance activities. Specific tasks completed under these contracts include:

Title V Reporting

  • Annual Compliance Certification Reports (CCRs) – Bluestone recently completed their third set of Annual CCRs for APG in March 2019. Preparation of the CCRs involved a compliance review of all Title V permitted sources and plant-wide conditions for the Aberdeen and Edgewood Areas.
  • Annual Emissions Certification Reports (ECRs) – For the past three years, the Bluestone team collected and compiled the information require to complete the ECRs required by the State of Maryland, for the emission units on the Title V permits for Aberdeen and Edgewood Areas. This review included an evaluation of operational and material data to determine if existing air emissions data were representative of each source’s emissions. This year’s reports were the third set of ECRs completed for APG under the Bluestone contracts. The data included emissions for various boilers, generators, paint spray booths, and miscellaneous units at APG.
  • Six-Month Monitoring (SIXMON) Reports – Bluestone is currently drafting the sixth round of SIXMONs for APG. As part of this subtask, Bluestone conducts semi-annual reviews of the Title V sources within Aberdeen and Edgewood Area, to determine compliance with applicable monitoring requirements.
  • Annual Visible Emissions Certification Reports – For the past three years, Bluestone has prepared two separate Annual Visible Emissions Certification Reports for APG, for boilers in the Aberdeen and Edgewood Areas. These reports summarize the field observations provided by the Garrison Inspector, and include boiler location, date of opacity determination, and results of opacity determination.
  • Semi-Annual Boiler Reports – Bluestone is currently preparing our sixth Semi-Annual Boiler Report for APG. This letter report is submitted to fulfill the reporting requirements for the control of sulfur oxide emissions from New Source Performance Standard (NSPS) boilers, as stated in the Aberdeen Proving Ground (APG) Title V permits.
  • Semi-Annual Safety Determinations for Open Burning – To date, Bluestone has prepared six Semi-Annual Open Burn Safety Determinations for APG. APG’s reports of anticipated or expected safety determinations is required under Code of Maryland Regulations, Open Fires and Safety Determinations at Federal Facilities. Completion of this task requires coordination with Aberdeen Test Center, the Directorate of Emergency Services (DES) Fire Department, and Army Research Laboratory.
  • Annual Greenhouse Gas (GHG) Reporting – For the past three years, Bluestone has submitted APG’s greenhouse gas data to the US Environmental Protection Agency’s (EPA’s) e-GRRT system for certification by the APG Air Program Manager.
  • Title V Renewal Packages for Aberdeen Area and Edgewood Area – In 2018-2019, Bluestone prepared draft renewal applications for the existing CAA Title V – Part 70 Operating Permits for the Aberdeen and Edgewood Areas. APG is currently awaiting comments from MDE on both permit applications.

General CAA Compliance Support

  • Record of Non-Applicability (RONA) Emissions Tool – In 2017, the Bluestone team updated APG’s RONA emissions tool and developed a Technical Guide for Compliance with the General Conformity Rule.
  • Ozone-Depleting Substances (ODS) Management Plan – Bluestone updated APG’s ODS Management Plan in 2017. In 2018-2019, Bluestone updated APG’s ODS inventory, met with Installation personnel, and revised APG’s ODS Compliance Memorandum.
  • APGR 200-30 Update – In September 2017, as part of our previous contract, Bluestone updated APG Regulation 200-30 to incorporate regulatory and general policy changes.
  • CAA Awareness Training – In May 2017, Bluestone provided CAA Awareness training to a total of 39 environmental professionals, facility managers, and equipment operators. Topics included an introduction to the CAA; an overview of air pollutants and attainment status; Aberdeen and Edgewood Area Title V Permit Conditions; regulatory requirements applicable to boilers, generators, paint spray booths, ODS equipment, asbestos management, and VOC sources; general conformity; and, Ozone Action Days. In May 2019, a refresher training course was presented to 36 attendees, which focused on the new ODS regulations and maintenance/recordkeeping requirements for boilers and generators.
  • Combustion Optimization (CO) Training – CO training is required every three years for boiler operators in accordance with COMAR 26 11-09.08-E(4) / F(1)(d). Bluestone conducted training in May 2017 (two sessions, 43 attendees) and May 2019 (one session, 35 attendees).
  • Toxic Air Pollutants (TAPs) Compliance Demonstration – A review was conducted in 2017, to assess if the existing sources of TAPs at APG are in compliance with the relevant provisions of COMAR 26.11.15 and .16. Actual emissions of TAPs were determined to be below allowable levels. Bluestone recommended that the analysis be repeated in the future when there is a significant change in emissions of Hazardous Air Pollutants (HAPs) or TAPs, resulting from either newly constructed emissions sources, or changes in the operation of existing sources.
  • Air Emissions Inventory Summary – Every three years, the State of Maryland is required by the U.S. Environmental Protection Agency to develop an inventory of air emissions in support of their State Implementation Plan. In April 2018, Bluestone prepared an air emissions inventory for APG (based on calendar year 2017 data), for nonpoint area sources (including commercial and consumer products, unpaved roads, boilers, fire training, generators, degreasing, and other site-specific operations); non-point off-road sources (including watercraft, aircraft operations, and other site-specific operations); and, mobile sources (including on-base traffic activities and other site-specific operations). Data for point sources were provided from the 2017 Emissions Certification Report.
  • Risk Management Plan (RMP) Support – In November 2016 and 2017, Bluestone updated APG’s RMP in EPA’s e-Submit System. In March 2017, Bluestone provided chlorine awareness training for the operators at the Edgewood Area-Van Bibber Water Treatment Plant, in response to an RMP deficiency. In October 2017, Bluestone provided support to APG during an RMP audit by the U.S. Environmental Protection Agency. Bluestone participated in the on-site meetings and provided documentation in response to EPA’s information requests.

In November/December 2017, Bluestone performed combined RMP/Process Safety Management (PSM) compliance audits at the Edgewood Area-Van Bibber Water Treatment Plant and the Aberdeen Test Center Climatic Test Facility, to the regulatory requirements outlined in 40 Code of Federal Regulations (CFR) CFR Part 68 and 29 CFR 1910.119. The review consisted of discussions with employees, reviews of various documents, and on-site observations of the processes. As a result of the review, regulatory findings (deficiencies) were identified and suggested corrective actions to address these deficiencies were provided. The audit report was finalized in April 2018.