&EPA
United States
Environmental Protection
Agency
Office of the Administrator
Washington, DC 20460
Mail Code 1807
EPA 100-R-00-028
January 2001
www.epa.gov/opei
Project XL Progress Report
Department of Defense:
Elmendorf Air Force Base—ENWEST
In 1995, the U.S. Environmental Protection Agency (EPA) embarked on a series of innova-
tive initiatives in an effort to test new ways to achieve greater public health and environmental
protection at a more reasonable cost. Through Proj ect XL, which stands for excellence and
Leadership, EPA enters into specific proj ect agreements with public or private sector spon-
sors to test regulatory, policy, and procedural alternatives that will produce data and experi-
ences to help the Agency make improvements in the current system of environmental protec-
tion. The goal of Proj ect XL is to implement 50 proj ects that will test ways of producing
superior environmental performance with improved economic efficiencies, while increasing
public participation through active stakeholder processes. As of January 2001, EPA has
reached its goal of 5 0 proj ects in the implementation phase. EPA Proj ect XL Progress
Reports provide overviews of the status of XL proj ects that are implementing Final Proj ect
Agreements (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL
Web site at http://www.epa.gov/Project XL. Hard copies may be obtained by contacting the
Office of Policy Economics and Innovation's (formerly the Office of Reinvention) Proj ect XL
general information number at 202-260-5754. Additional information on Proj ect XL is
available on the Web site or by contacting the general information number. The information
and data presented in the January 2001 Progress Report is current as of December 2000.
As part of the Clinton Administration's initiative to reinvent environmental regulations, EPA
and the DoD signed a Memorandum of Agreement (MO A) in 1995 that established how the
two agencies would interact during DoD's implementation of the ENWEST program. The
MOA established a framework for developing ENWEST pilot programs at three to five
DoD facilities. The ENWEST program emphasizes regulatory compliance through pollution
prevention and provides an alternative to prescriptive regulatory requirements through a
performance-based environmental management system designed to attain superior environ-
mental results. Elmendorf Air Force Base
(Elmendorf AFB) has been selected as
one of the prototype DoD
facilities to pilot the
ENWEST program and to
implement cost-effective
environmental -
protection. "v^.—
Elmendorf Air
Force Base
Anchorage,
Alaska
Major Milestones
• /
April 2, 1998
Elmendorf AFB XL
Proposal Submitted
7
December 15, 1999
Final Project Agreement
Signed
/
March 24, 2000
Initial ENVVEST
Progress Report
Completed
/
Summer 2000
Construction of
Compressed Natural Gas
Station
7 •
December, 2004
Final Commitments
to Be Met
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Elmendorf Air Force Base XL Project 1-31-01
Background
Elmendorf AFB is located just north of Anchorage, the largest city in Alaska. Elmendorf AFB covers approxi-
mately 13,000 acres; it has more than 800 buildings, two runways, more than 150 miles of roads, and more
than 7,500 personnel from all branches of the United States and Canadian armed forces. With civilian workers,
retirees, and their families, the number of people associated with Elmendorf rises to nearly 25,000. The 3rd
Wing, the host unit for Elmendorf AFB provides air superiority and air defense forces to the commander-in-
chief, North American Aerospace Defense Command, as well as mobile, composite tactical air, airlift, and
airborne warning and control forces to the commander-in-chief, U.S. Pacific Command.
Anchorage is currently classified as a serious nonattainment area for the Federal carbon monoxide (CO) stan-
dard under the Clean Air Act (CAA) National Ambient Air Quality Standards (NAAQS). The southern bound-
ary of the base borders the Anchorage nonattainment area. Elmendorf is not included in the nonattainment area,
therefore reductions in pollution levels for Elmendorf AFB are not required under Title V requirements, a
national permit system that applies to maj or stationary sources of air pollution under the CAA. Nevertheless,
one of the goals of this XL/ENWEST proj ect is emissions reductions on the base, including CO.
Through this XL/ENWEST project, Elmendorf AFB will increase its pollution prevention activities using
funding that would otherwise be spent complying with the administrative requirements of Title V, such as permit-
ting, record keeping, monitoring, and training. Elmendorf AFB estimates that overall administrative and permit
management costs will decrease by about 80 percent, yielding about $1.5 million in savings over six years.
These realized cost savings will be directed toward pollution prevention (P2) activities. AP2 project already
identified involves installing a compressed natural gas (CNG) fueling station, purchasing new CNG vehicles, and
converting certain base fleet vehicles to allow them to use CNG as an alternative fuel. Additional proj ects, with
an emphasis on those that reduce hazardous air contaminants (HACs), are under consideration. Potential areas
of HAC reduction include surface coating operations, internal combustion engines, incinerators, gasoline distri-
bution, and aircraft engine testing.
The Experiment
The Elmendorf AFB project aims to finance P2 activities with the cost savings and paperwork reduction associ-
ated with simplified Title V requirements. Under the simplified requirements, the Elmendorf central heating and
power plant (CH&PP) will be permitted as the base's only major stationary source, based on its emissions of
nitrogen oxides (NOx) (greater than 100 tons per year) and CO (greater than 100 tons per year). In addition,
the Alaska Department of Environmental Conservation (ADEC) will approve potential to emit (PTE) limits for
the remaining sources, substantially reducing reporting requirements. Without these changes, Elmendorf AFB
would be required to include over 100 sources of regulated contaminants for its Title V permit. In total, these
administrative changes are expected to result in savings of approximately $1.5 million over a six year period.
This savings will be reinvested in pollution prevention activities on base, with an emphasis on hazardous air
contaminants (HACs) emission reduction. This XL/ENWEST proj ect will demonstrate the feasibility of alter-
native-fuel vehicles in the Anchorage area, and reduce air pollution base wide through pollution prevention at
multiple minor sources.
The Flexibility
As an incentive to achieve superior environmental performance at Elmendorf AFB, EPA and the ADEC are
allowing more flexible and cost-effective processes for regulatory management. The statutory programs affecting
the Elmendorf XL/ENWEST proj ect are the CAA programs administered by EPA's Office of Air Quality
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Elmendorf Air Force Base XL Project 1-31-01
Planning and Standards.
Streamlining the Regulatory Process. The XL/ENVVEST proj ect will provide Elmendorf AFB with relief
from ADEC's operating permit program for maj or stationary sources by creating a single, comprehensive permit
that includes all CAA requirements for a maj or stationary source of air pollution. The traditional Alaska operat-
ing permit program would treat Elmendorf AFB as a single air contaminant emission source, with 106 sources of
regulated contaminants that would need to be addressed in its Title V permit. Under these circumstances, the
costs of obtaining and maintaining a Title V permit would be substantial. Under this XL proj ect, the Title V
permit would apply to only a small segment of Elmendorf AFB, including one source that is a maj or stationary
source, the CH&PP, and several others that are subject to new source performance standards. ADEC will
establish PTE limits for the other sources at Elmendorf AFB to ensure that they are not considered maj or
sources. To enable the regulatory changes under this XL/ENWEST proj ect, ADEC will work toward inclusion
of the major source guidance for Elmendorf AFB into the Alaska Air Quality Control regulations, 18 AAC 50.
Most of the flexibility provided by this proj ect could have been obtained without Proj ect XL through a August
2,1996, policy guidance document entitled, "Major Source Determinations for Military Installations under the
Air Toxics New Source Review, and Title V Operating Permit Programs for the Clean Air Act," and with the
imposition of PTE limits on Elmendorf AFB. However, by participating in this XL Proj ect, Elmendorf AFB
obtains the flexibility to redirect money that would have been spent on Title V costs into P2 proj ects. Elmendorf
AFB has agreed to invest the expected savings of $1.5 million into projects that will result in actual emission
reductions. Without the XL/ENWEST project, those programs probably would have not otherwise occurred.
Stationary Source Classification. The EPA policy guidance recognizes that military installations possess unique
characteristics warranting flexibility in major source determinations similar to that available to industry under
EPAs regulations and policies. The guidance allows military installations under common control to divide into
functionally distinct emitting activities. The primary activities of the installation and their emission sources can be
separated from the support activities and their emission sources. For example, separating emission sources
directly supporting flight line operations from emission sources such as housing. To that end, the base has utilized
the guidance to divide the 106 emission sources into 11 functionally distinct emitting activities by using common
control classifications and the Standard Industrial Classification (SIC) Code manual. Major stationary sources
covered by National Emission Standards for Hazardous Air Pollutants (NESHAPs) and New Source Perfor-
mance Standards under the CAA will be included in the Title V permit, if applicable. On the basis of PTE, a
number of emission sources would be considered maj or stationary sources. However, only one of the emission
sources, the CH&PP, is a truly maj or stationary source based on its actual emissions of NOx (greater than 100
tons per year) and CO (greater than 100 tons per year).
Potential to Emit Limits. In addition, Elmendorf AFB will use a three-pronged mechanism to limit the PTE of
several other activities occurring on base. Because actual emissions from many of these sources are consider-
ably below applicable maj or source thresholds, the base will seek and apply limits on the PTE from these
sources. The base will apply for Preapproved Limits for 39 emergency diesel engines under Alaska permits.
The base will also apply for a state permit to cover base-wide HACs under Owner Requested Limits set forth
in existing state regulations (18 AAC 50.225). These alternative emission standards create practicably enforce-
able limits and are a necessary part of the permitting scheme under this proj ect. The administrative costs associ-
ated with these PTE limits are expected to be minimal because the base already tracks much of the necessary
reporting information. Approval of these limits means Elmendorf will not be a maj or source of HACs, and
therefore the administrative burden of reporting is greatly reduced. Without approval of these limits, Elmendorf
could be considered a major source of HACs and be required to have a base-wide permit. A revised Emissions
Inventory will be submitted to ADEC as the basis for establishing the limits. PTE limits are expected to be in
place by January 2001.
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Elmendorf Air Force Base XL Project
1-31-01
Environmental Stewardship. Elmendorf AFB is committed to spending the savings derived from streamlining
its environmental management costs on P2 opportunities. One such P2 proj ect identified in the FPA involves
installation of CNG fueling station, the purchase of new CNG vehicles, and the conversion of certain base fleet
vehicles to be capable of using CNG as an alternative fuel. Another P2 proj ect being considered is the imple-
mentation of Clean Cam Technology Systems (CCTS) at Elmendorf AFB. By replacing engine parts in diesel-
powered engines, CCTS can dramatically reduce air emissions, including CO, NOx, and particulate matter.
Elmendorf AFB plans to install CCTS on at least one of the base's A/M32A-86 generators to test the effective-
ness of CCTS in the arctic climate, with an eye to using the technology if it proves appropriate. Elmendorf AFB
has assembled a list of other feasible P2 opportunities available at the base, along with the estimated costs and
environmental benefits of each opportunity. In addition, EPA, the State of Alaska, and Elmendorf AFB have
expressed a preference for HAC reduction projects. A supplemental agreement setting forth the specific addi-
tional P2 opportunities to be implemented will be developed with the assistance of stakeholders.
Promoting Innovation and System Change
Proj ect XL provides EPA opportunities to test and implement approaches that protect the environment and
advance collaboration with stakeholders. EPA is continually identifying specific ways in which XL proj ects are
helping to promote innovation and system change. The innovations and system changes that have emerged from
the Elmendorf AFB XL project are described below.
Permit Reform. Title V of the Clean Air Act establishes an approach to source-specific regulation by requiring
each state to develop and implement an operating permit program for all Major Stationary Sources (42 U. S.C.
§ 7661 etseq) of air pollution and other stationary sources subject to requirements under Sections 111, 112,
129, or Title IV of the Clean Air Act. The current Alaska operating permit program would treat the entire
Elmendorf installation as a single air contaminant [AS 46.14.990(1)] emission source for the purpose of deter-
mining if a state-issued Clean Air Act Title V permit is required. The 1996 base emissions inventory, in support
of the base's Title V permit application, lists 106 sources of regulated contaminants
[AS 46.14.990(23)] that would need to be addressed in the permit. Using the current Alaska permitting ap-
proach, the costs of obtaining and maintaining a Title V permit would be very significant for the installation.
Under this XL proj ect, the Title V permit would apply to only one source that is a maj or stationary source, the
CH&PP, and several others that are subject to new source performance standards. ADEC will establish PTE
limits for the remaining sources that will not be permitted to ensure that they are not considered maj or sources.
Federal Budget Process. As with other ENWEST proj ects, Elmendorf AFB is testing new approaches to the
Federal budgeting process. In the past, DoD's budgeting process allowed resources meant for environmental
protection to be used only for meeting legally mandated environmental protection levels. New approaches are
being tested to create a budget process that allows DoD to spend resources on pollution prevention programs,
innovative technologies, and other cost-effective approaches that will reduce emissions below legally mandated
levels.
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Elmendorf Air Force Base XL Project
Project Commitment Summary
1-31-01
This table and the environmental performance section that follows summarize progress in meeting commitments
described in the FPA for the Elmendorf AFB XL/ENWEST proj ect:
Commitment | Status
Elmendorf Commitments
Construction of compressed natural gas fueling
station.
Fleet vehicle conversion.
Supplementary Agreement on additional pollution
prevention proj ect(s).
Construction complete in summer 2000, and cel-
ebrated with a ribbon cutting ceremony in Septem-
ber 2000.
Elmendorf AFB purchased conversions for 15
vehicles in 2000 and anticipates 1 1 more in 2001 .
To be completed before end of F Y 200 1 .
EPA Commitments
Provide technical and administrative assistance to
Elmendorf and ADEC.
Review and, as appropriate, approve regulatory
relief approaches adopted by ADEC.
As needed.
As needed.
ADEC Commitments
Provide technical assistance to Elmendorf regarding
opportunities for HAC and criteria pollutant emission
reductions.
Issue a Title V permit.
Assist Elmendorf with efforts to calculate the PTE of
emission sources on the base.
As needed.
Anticipated following establishment of PTE limits.
Draft Emissions Inventory has been submitted to
ADEC.
Environmental Performance
This section summarizes the progress in meeting the environmental performance described in the FPA for
Elmendorf AFB. The goals and baselines for specific pollution prevention activities and performance objectives
will be developed in a supplemental agreement, to be signed no later than September 30,2001.
Pollution Prevention Activities. One of the pollution prevention projects that will take place is the installation
of CNG fueling station on the base, the conversion of certain base fleet vehicles to be capable of using CNG as
well as the procurement of dual fuel and dedicated CNG fuel vehicles. Converted vehicles will be tested to
ensure they result in reduced emissions, manufactured dual fuel and dedicated fuel vehicles will also be analyzed
to ensure positive environmental performance. Each type of vehicle to be converted will be tested before
conversion to establish emission baselines, and following conversion to ensure positive results. The completion
of the CNG fueling station at Elmendorf, one of the first in the country located on an Air Force base, and the
conversion of Elmendorf vehicles will facilitate the Air Force in meeting its commitments to the Energy Policy
Act of 1992 by reducing dependence on foreign sources of petroleum and reducing air emissions, and a sepa-
rate executive order requiring Federal agencies to acquire alternative fuel vehicles.
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Elmendorf Air Force Base XL Project
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The cleaner-burning CNG vehicles will contribute to reduced
CO emissions for Elmendorf and will demonstrate that this
level of technology is achievable and beneficial in Anchorage
and Alaska. CO is a product of the incomplete combustion
of fossil fuels and is emitted directly from the tailpipe of
vehicles. CO enters the bloodstream through the lungs and
forms carboxyhemoglobin, a compound that inhibits the
blood's capacity to carry oxygen. People with heart disease
are particularly sensitive to CO poisoning. Infants, the elderly,
and individuals with respiratory diseases are also sensitive
receptors. CO can also affect healthy people by impairing the
capacity to exercise, visual perception, manual dexterity,
learning functions, and the ability to perform complex tasks.
Construction of the CNG fueling station was completed
during the summer, 2000, and commemorated in a ribbon-
cutting ceremony in September. Elmendorf purchased 15
conversions to dual-fuel systems in fiscal year 2000, with the
first set of five vehicles delivered to the Base in November.
Eleven more vehicle conversions are planned during fiscal
year 2001.
Elmendorf AFB is also considering the installation of CCTS
in generators on base. By replacing engine parts in diesel-
powered engines, CCTS can dramatically reduce air emis-
sions. Limited testing of the technology at Brooks Air Force
Base, Texas, has demonstrated significant air emission
reductions on generators: hydrocarbon emissions by 44 percent, CO emissions by 43 percent, NOx emissions
by 77 percent, and particulate matter emissions by 52 percent. Elmendorf AFB plans to install CCTS on at least
one of the base's 86 generators to test the effectiveness of CCTS in the arctic climate. If such dramatic emis-
sions reductions are seen, it is likely that the XL/ENWEST proj ect will include further CCTS conversions.
Elmendorf has assembled a list of other feasible pollution prevention opportunities available at the base, along
with the estimated costs and environmental benefits of each opportunity. In conjunction with ADEC and
Elmendorf AFB, additional pollution prevention activities will be determined. A supplemental agreement will be
signed no later than September 3 0,2001, setting forth the opportunities selected and any necessary measures to
ensure their performance.
Stakeholder Participation
Elmendorf AFB held several public meetings to request input on the proj ect, including presenting the proposal to
three local community councils. These meetings were publicized through local newspapers and personal con-
tacts. The comment and EPA's response are attached to the FPA. Public meetings will continue throughout the
course of the proj ect, in order to further examine and decide on additional HAC emissions reduction and P2
activities. Finally, the Restoration Advisory Board (RAB), which includes representatives of most of the local air
quality organizations, meets regularly and is an avenue by which the XL project status is reported to stakehold-
ers. The goal of the RAB, created in 1994, is to provide a forum to enhance the communication and coordina-
tion among the Air Force, EPA, ADEC, and affected communities in response to actions undertaken by the
Environmental Restoration Program at Elmendorf. Elmendorf representatives brief the RAB on all important
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Elmendorf Air Force Base XL Project 1-31-01
environmental issues, including the progress of the XL/ENWEST proj ect.
The XL/ENWEST Team at Elmendorf AFB will inform the stakeholders as the project evolves, in accordance
with the Public Outreach Plan. Elmendorf AFB will prepare progress reports at least annually, in conjunction
with submittal of the facility operating report to ADEC or on a basis agreed to by all stakeholders, which will
document progress toward the goals of this XL project.
Six-Month Outlook
The key focus areas for continued successful implementation of the FPA over the next six months will be the
following:
• Complete and open the CNG station.
• Continue implementation of CNG vehicle conversion on base and procure additional dual-fuel vehicles.
• Negotiate and select additional pollution prevention activities with stakeholders.
• Establish FIACPTE limits with ADEC.
Project Contacts
• Dave Bennett, Elmendorf Air Force Base, (907)-552-2760.
• Will Garvey, Federal Facilities/ENVVEST, (703)-564-2458.
• John Stone, State of Alaska, (907)-465-5103.
• David Bray, EPA Region 10, (206)-553-4253.
• Nancy Birnbaum, EPA Headquarters, (202)-260-2601.
Information Sources
The information sources used to develop this progress report include (1) the Final Project Agreement for the
Elmendorf AFB XL/ENWEST project (December 1999), (2) supplementary proposal materials, and (3) the
Initial ENWEST Progress Report (March 24,2000). The information sources are current through July 2000.
Glossary
Baseline: The measure by which future environmental performance can be compared.
Clean Air Act (CAA): The CAA is the comprehensive Federal law that regulates air emissions from area,
stationary, and mobile sources. This law authorizes the EPA to establish National Ambient Air Quality Stan-
dards (NAAQS) to protect public health and the environment.
Compressed Natural Gas (CNG): A purified form of natural gas (methane), suitable for use as a substitute for
gasoline or diesel fuel.
Criteria Air Pollutants: The CAA requires EPA to set NAAQS for certain pollutants known to be hazardous to
human health. EPA has identified and set standards to protect human health and welfare for six criteria air
pollutants—ozone, carbon monoxide, total suspended particulates, sulfur dioxide, lead, and nitrogen oxide. EPA
must describe the characteristics and potential health and welfare effects of these pollutants. It is on this basis
that standards are set or revised.
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Elmendorf Air Force Base XL Project 1-31-01
Maj or Stationary Source: In a nonattainment area, any stationary pollutant source with the potential to emit
more than 100 tons per year is considered a maj or stationary source. The cutoff emissions levels are lower for
more seriously polluted areas. The classification is used to determine the applicability of Prevention of Significant
Deterioration (PSD) and New Source Review (NSR) regulations.
Memorandum of Agreement (MO A): An agreement between Federal agencies or divisions within an agency or
department that delineates tasks, jurisdictions, standard operating procedures, or other matters that the agencies
are duly authorized and directed to conduct.
Minor Source: New emissions sources or modifications to existing emissions sources that do not exceed
NAAQS emission levels.
National Ambient Air Quality Standards (NAAQS): Regulations promulgated by EPA under the CAA for six
criteria pollutants—sulfur dioxide, paniculate matter, nitrogen dioxide, carbon monoxide, ozone, and lead—to
protect the public from toxic emissions to the atmosphere.
Nitrogen Oxides (NO x ): An air pollutant that is the result of photochemical reactions of nitric oxide in ambient
air. Typically, it is a product of combustion from transportation and stationary sources. It is a maj or contributor
to the formation of ozone in the troposphere, photochemical smog, and acid deposition.
Nonattainment Area: A geographic area in which the level of a criteria air pollutant is higher than the level
allowed by the Federal standards. A single geographic area may have acceptable levels of one criteria air
pollutant but unacceptable levels of one or more other criteria air pollutants; thus, an area can be both in attain-
ment and nonattainment at the same time. It has been estimated that 60 percent of Americans live in
nonattainment areas. Based on the severity of the problem, nonattainment areas are classified as marginal,
moderate, serious, severe, and extreme.
Potential to Emit (PTE): A pollution source's total PTE is determined by a two-step process. First, the source's
potential emissions at maximum physical capacity are established. This is then reduced by any recognized limits
on the source's emissions, such as limits on rates of production, hours of operation, and type and amount of fuel
burned or materials processed. The PTE is a significant factor in regulations implementing the Title V operating
permits program.
Retrofit: To furnish with new parts or equipment not available at the time of manufacture.
Stationary Source: A stationary place or obj ect from which pollutants are released. Stationary sources include
power plants, gas stations, incinerators, and houses.
Title V of the Clean Air Act: Title V establishes a Federal operating permit program that applies to any maj or
stationary facility or source of air pollution. The purpose of the operating permits program is to ensure compli-
ance with all applicable requirements of the CAA. Under the program, permits are issued by states or, when a
state fails to carry out the CAA satisfactorily, by EPA. The permit includes information on which pollutants are
being released, how much may be released, and what kinds of steps the source's owner or operator is taking to
reduce pollution, including plans to monitor the pollution.
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