United States
                    Environmental Protection
                              Office of Reinvention
                              Washington, DC 20460
                              Mail Code 1802
                       EPA/1 OO/F-99/008
                       March 1999
  &EPA       XL  Project  Progress Report
                    Vandenberg Air Force  Base—ENWEST
On March 16,1995, the Clinton Administration announced a portfolio of reinvention initia-
tives as a part of its efforts to achieve greater public health and environmental protection at a
more reasonable cost. The initiatives included Proj ect XL to be implemented by the U.S.
Environmental Protection Agency (EPA), and the Environmental Investment (ENWEST)
program to be implemented by the Department of Defense. Through Proj ect XL, which
stands for excellence and Leadership, EPA enters into specific proj ect agreements with
public or private sector sponsors to test regulatory, policy, and procedural alternatives that
will produce data and experiences to help the Agency make improvements in the current
system of environmental protection. The goal of Project XL is to implement 50 projects that
will test ways of producing superior environmental performance with improved economic
efficiencies, while increasing public participation through active stakeholder processes. As of
October 1998,10 XL proj ects are in the implementation phase and 20 XL proj ects are
under development. Proj ect XL Progress Reports provide proj ect-specific overviews of the
status of individual XL proj ects that are implementing Final Proj ect Agreements (FPAs). The
progress reports are available on the Internet via EPA's Proj ect XL web site at http://
www.epa.gov/ProjectXL. Or, hard copies may be obtained by contacting the Office of
Reinvention's Project XL Docket at 202-260-7434. General information on Project XL is
available on the web site or by contacting the general information number at 202-260-5754.

As part of the Clinton Administration's initiative to reinvent environmental regulations, EPA
and the Department of Defense (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 regula-
tory compliance through pollution prevention and provides an alternative to prescriptive
regulatory requirements through a
performance-based environmen-
tal management system designed
to attain superior environmental
results. Vandenberg Air Force
Base (AFB) has been selected as
                    the prototype DoD facility to pilot
                    the ENWEST program and
                    implement cost-effective
                    environmental protection.
                             Air Force Base
       Major Milestones
           April 16, 1996
       Vandenberg XL Proposal
                 October 23, 1996
               Stakeholder Workshop
  Novembers, 1997
Final Project Agreement
  November 30,2002
Final FPA Commitments
     to be Met

Vandenberg XL Project                                                                     13-31-99)
 The 30th Space Wing at Vandenberg AFB conducts and supports space and missile launches, operates the
 Western Test Range, and responds to worldwide military contingencies. Vandenberg AFB covers more than
 98,000 acres and is the Air Force's third-largest installation. It is located in Santa Barbara County on the central
 coast of California, 150 miles northwest of Los Angeles.
 Through this XL/ENVVEST project, Vandenberg AFB will upgrade ozone precursor emission controls using
 money that otherwise would be spent complying with the administrative requirements of Title V of the Clean Air
 Act (CAA), such as permitting, record keeping, monitoring, and training. When Vandenberg AFB reduces
 ozone precursor emissions to agreed-upon levels, its designation under Title V as a maj or source of ozone
 precursor emissions will be reduced to a designation as a minor source, which will result in a substantial reduc-
 tion in compliance costs for Vandenberg AFB.

 Vandenberg AFB will apply advanced emission control technologies to the stationary ozone precursor sources
 that will afford the greatest emission reductions. Vandenberg AFB will implement a phased program to reduce
 air emissions of ozone precursors. In the short term, obtaining reductions has focused on boilers, furnaces, and
 process heaters. The feasibility of modifying boilers rated from 2 to 5 million British thermal  units (Btus) per hour
 was assessed first because they are Vandenberg AFB's single largest stationary source of ozone precursor
 emissions. In the long term, Vandenberg AFB will focus on the pollution prevention opportunities for emission
 reductions from a variety of other sources of ozone precursors, including internal combustion engines and
 solvent and surface coating applications. Details of the program are specified in an enforceable emission reduc-
 tion plan prepared by Vandenberg AFB. The plan is available from Vandenberg AFB.

 Vandenberg AFB will improve the air quality of Santa Barbara County by using innovative technologies to
 reduce annual emissions of ozone precursors by 10 tons or more by November 30,2002.

 The XL/ENVVEST proj ect will provide Vandenberg AFB with relief from the Santa Barbara County Air
 Pollution Control District's (the District's) operating permit program for major stationary sources. The major-
 source operating permit program is an EPA-approved permit program implementing EPA regulations under Title
 V of the CAA. The obj ective of this operating permit program is to create a single, comprehensive permit that
 includes all CAA requirements for a major stationary source of air pollution. The statutory program and EPA
 office administering the program that aifects the Vandenberg AFB XL/ENVVEST proj ect are CAA programs
 administered by EPA's Office of Air Quality Planning and Standards.

 All air quality permitting programs required to implement the CAA requirements have been delegated by EPA to
 the State of California. California has delegated permitting authority to the County of Santa Barbara. Permits are
 issued by the District.
 Stationary Source Classification. Vandenberg AFB, like other military installations, differs from civilian or
 industrial stationary sources in that the base hosts and supports a unique and wide variety of functions and
 activities. These activities include residential housing, schools, recreational parks, wildlife reserves, shopping
 centers, industrial maintenance, airfield operations, and various other mission-related activities. Vandenberg
 AFB creates criteria pollutants normally associated with residential, commercial, and light industrial operations.
 Most of the stationary source ozone precursor emissions (primarily nitrogen oxides) are generated by boilers,
 furnaces, process heaters, and internal combustion engines.

 Vandenberg XL Project                                                                     13-31-99)
For purposes of permitting, EPA and the District historically have considered Vandenberg AFB and all of its
individual emission units to be a single stationary source. Vandenberg AFB is a military installation with a unique
space launch mission for military, commercial, and scientific projects. However, Vandenberg AFB does not fit
the single stationary source definition as generally applied to civilian or industrial sources.
Vandenberg AFB, in cooperation with the District and EPA Region 9, determined that, if the actual emissions
that are used to make a maj or stationary source determination for the base could be reduced to minor source
levels, then Vandenberg AFB would be eligible to comply with rules that entail significantly less of an adminis-
trative burden. The District's Rule 31'0, Potentialto Emit—Limitations for Part 70 Sources, allows station-
ary sources that emit minor source levels of criteria! pollutants to comply with Rule 3 70 requirements rather
than having to obtain a Title V operating permit, thereby decreasing the permit administrative requirements for
Vandenberg AFB.
Together, the District, EPA Region 9, and Vandenberg AFB applied EPA guidance to group different base
activities (for example, hospital services and base amenities) as separate stationary sources for purposes of
Title V applicability only. In addition, the District amended its rules and regulations to exclude from its major
source determination emi ssions that meet EPA's definition of "non-road engine," including equipment used for
tactical support, infrastructure, and maintenance. These amendments are contingent upon Vandenberg AFB
meeting the milestones of the FPA and ultimately reducing annual emissions of ozone precursors by at least 10
tons by November 30,2002. Together, these areas of regulatory flexibility allowed the XL/ENVVEST project
to proceed and Vandenberg AFB to be redesignated as a minor stationary source pursuant to Rule 370.

Permit Administrative Requirements. Vandenberg AFB will use the funds that otherwise would be spent to
comply with the administrative requirements of the major source operating permit program to reduce emissions
by upgrading combustion equipment on ozone precursor emission sources.


Proj ect XL/ENWEST provides DoD and EPA opportunities to test and implement approaches that protect
the environment and advance collaboration with stakeholders. DoD and EPA are continually identifying specific
ways in which XL and EN WEST proj ects are helping to promote innovation and system change. The innova-
tions and system changes that have emerged from the Vandenberg AFB XL/ENVVEST project are described

Administrative Burden Reduction. A number of XL proj ects  are testing different approaches to reducing the
administrative permitting requirements imposed by Federal, state, and local regulations. The Vandenberg AFB
proj ect is a test-bed for sector-wide burden reduction for Federally regulated entities. EPA is undertaking a
coordinated permitting reform effort. Lessons learned from the Vandenberg AFB XL/ENVVEST permit
approach will be used to influence the Permit Reform Action Plan.
Federal Budget Process. ENWEST is testing new approaches to the Federal budgeting process. In the past,
DoD's budgeting process allowed resources meant for environmental protection activities to be used only to
meet 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 approaches that will cost-effectively reduce emissions below legally mandated levels.

Vandenberg XL Project

 This section summarizes project commitments described in the Final Project Agreement (FPA) for Vandenberg
 AFB in California.
Commitment | Status
Emission Reduction Planning and Permitting
Vandenberg AFB will complete the initial assessment
and cost feasibility study within 30 days of executing
the FPA.
The District will provide technical assistance to
Vandenberg AFB in development of Rule 1301
emission reduction plan.
Vandenberg AFB will develop aRule 1301 emission
reduction plan and submit to the District no later than
November 30, 1997.
The District will review and approve the Rule 1301
emission reduction plan.
EPA will review and approve District rule changes.
Initial assessment and cost feasibility study completed
on November 26, 1 997.
The District's innovative technologies group has
provided technical assistance for the development of
the emissions reduction plan.
Plan and protocols submitted November 26, 1997.
Plan partially approved on February 20, 1 998.
District Rule 370 approved on December 15, 1997.
District Rule 1301 approved on December 15, 1997.
Source Identification and Replacement
Vandenberg AFB will complete the final evaluation of
the 29 pre-selected candidate boilers to determine
their eligibility and feasibility for retrofit or replacement
with low-NOx technology by October 30, 1998.
Vandenberg AFB will retrofit or replace 30% of
candidate boilers by April 30, 1999, and 70% of
candidate boilers by April 30, 2001 , with a goal of
reducing annual emissions of ozone precursors by 2
tons by April 30, 2000, and by 10 tons or more by
November 30, 2002.
Vandenberg AFB will assess emission reduction
potential from solvents, surface coatings, and other
Vandenberg AFB submitted a final candidate boiler
list on October 29, 1998.
Vandenberg AFB retrofitted or replaced 71 % of the
candidate boilers with low-NOx technology, all
achieving less than 20 parts per million (ppm), by
January 1999.
Work is in progress on the application of low and
zero VOC coating substitutions for both architectural
coating and corrosion-control operations.
Vandenberg AFB will prepare progress reports 30
days after FPA signing and every 6 months thereafter.
Initial progress report was completed on December
2, 1997.
Semi-annual progress report was completed on June
29, 1998.
Semi-annual progress report was completed in
January 1999.

 Vandenberg XL Project
                                     Stakeholder Meetings
  Vandenberg AFB will conduct public meetings.
Stakeholder updates provided at Community
Advisory Board meetings on August 22,1997;
November 21, 1997; and June 4, 1998. Next
stakeholder meeting scheduled for March 19,1999.

This section summarizes Vandenberg AFB's progress in meeting environmental performance commitments
described in the FPA.
Nitrogen Oxide (NOJ Emissions: Vandenberg AFB has
committed to reducing annual emissions of ozone precursors by 2
tons per year by April 30,2000, and by 10 tons per year or more
by November 30,2002. Reductions in the ozone precursor, NO,,
will be accomplished by retrofitting or replacing those boilers with
the highest potential for emission reductions.

Progress: Actual emissions data have been collected from the 29
pre-selected candidate boilers to determine baseline emission
levels and the potential emission reduction resulting from a boiler
retrofit/replacement proj ect. Six boiler retrofit/replacement proj ects
have been initiated. Data on the reduction of NOx emissions (in
tons per year) from these boiler retrofit/replacement projects will
be available in the next Vandenberg AFB progress report.
                       Ozone Precursor Emissions
       November 30, 2002 Goal
          April 30, 2000 Goal
        Baseline (1996 Levels)
                                    40      60
                                  Tons per year
Volatile Organic Compound (VOC) Emissions: Vandenberg AFB has committed to reducing annual
emissions of ozone precursors by 2 tons per year by April 30,2000, and by 10 tons per year or more by
November 30,2002. Reductions in the ozone precursor, VOCs, will be accomplished by assessing the
emission reduction potential from solvents, surface coatings, and other sources of VOC emissions.
Progress: On January 19,1999, Vandenberg AFB received approval from the SBAPCD on VOC reduction
initiatives presented on March 3,1998. The SBAPCD defined the extent of surplus emissions available to the
ENVVEST program with respect to these reduction initiatives. Targeted VOC reductions will entail the
application of low and zero VOC coating substitutions for both architectural coating and corrosion-control

Vandenberg AFB has involved its stakeholders in formulating the FPA and has met with stakeholders three
times to discuss the initiative and receive input. The organizations directly involved in negotiating the FPA
included Vandenberg AFB, EPA Region 9, EPA Headquarters, Santa Barbara County Air Pollution Control
District, the Vandenberg AFB Community Advisory Board, and the District Community Advisory Council.
The Vandenberg AFB Community Advisory Board (CAB) was originally organized to promote community
awareness and review the remedial cleanup process at Vandenberg AFB. The role of the CAB has been
expanded to address negotiation and implementation of the Vandenberg AFB XL/ENWEST project. Repre-

Vandenberg XL Project                                                                   13-31-99)
  sentatives on the CAB include residents of Santa Maria, Lompoc, Vandenberg AFB, and Santa Ynez; commu-
  nity service districts of Mission Hills and Vandenberg Village; local high schools and colleges; California EPA
  Department of Toxic Substances Control; Santa Barbara County Air Pollution Control District; county and city
  Fire Departments and Public Works Departments; and the California Regional Water Quality Control Board.

  The District Community Advisory Committee (CAC) provides advice regarding air quality issues to the Santa
  Barbara Air Pollution Control District Board of Directors. Each member of the Board appoints two community
  members to serve on the CAC. The CAC has formed a subcommittee to assist the District oversee the execu-
  tion of the FPA.

  Vandenberg AFB efforts to continue stakeholder involvement include:
  • Issuing press releases;
  « Running information notices in local newspapers;
  • Sponsoring public meetings; and
  • Working with the CAB and CAC.
  Public meetings related to the Vandenberg AFB XL/ENVVEST projectbegan in October 1996 and will
  continue every six months after execution of the FPA. The purpose of the meetings is to advise interested
  members of the public on the progress toward meeting FPA goals. The meetings inform the public of the steps
  taken to reduce pollution, include information on proposed steps to meet the goals of the FPA, and solicit
  comment from the public.

  The key focus areas for continued successful implementation of the FPA over the next six months will be the
  « Continue stakeholder meetings.
  • Continue to retrofit candidate boilers to meet FPA milestones.
  « Resolve issues of surplus emissions as they pertain to Vandenberg AFB's proposed emission reduction
    initiatives for internal combustion engines (booster pump and compressors), architectural coatings, corro-
    sion-control and paint-booth applications, sustainable housing development, and on-road mobile sources.

  • Monte D. McVay, Vandenberg AFB, 805-734-8232 ext. 52015
  « Maureen Sullivan, Department of Defense Headquarters, 703-604-0519
  • Peter Cantle, Santa Barbara County Air Pollution Control District, 805-961-8927
  • Sara Segal, EPA Region 9, 415-744-1569
  • Chri stopher Knopes, EPA Headquarters, 202-260-9298

  The information sources used to develop this progress report include: 1) discussions during a teleconference
  among representatives of the U. S. Environmental Protection Agency, Santa Barbara County Air Pollution
  Control District, Vandenberg AFB, and Department of Defense; 2) the Final Proj ect Agreement for the
  Vandenberg AFB XL/ENVVEST proj ect; and 3) annual and semi-annual status reports prepared by
  Vandenberg AFB. The information sources are current through December, 1998.

 Vandenberg XL Project                                                                    13-31-99)

British thermal unit (Btu): A unit of heat energy equal to the amount of heat required to raise the temperature of
one pound of water by one degree Fahrenheit at sea level.
Clean Air Act (CAA): The Clean Air Act is the comprehensive Federal law that regulates air emi ssions from
area, stationary, and mobile sources. This law authorizes the EPA to establish National Ambient Air Quality
Standards (NAAQS) to protect public health and the environment.
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 characteri sties and potential health and welfare effects of these pollutants. It is on thi s
basis that standards are set or revised.

District Rule 1301: Rule 1301 was adopted by the Santa Barbara County Air Pollution Control District to
implement EPA regulations governing stationary source operating permits in Santa Barbara County.

District Rule 370: Rule 370 was adopted by all Air Quality Control Districts in Californiato clarify the applica-
bility of EPA regulations governing stationary source operating permits. Rule 370 defines major, minor, and
synthetic minor stationary source classifications (and exemptions), and therefore, spells out the requirements
that must be met by Vandenberg AFB to be eligible for designation as a minor stationary source.
Major stationary source: Term used to determine the applicability of Prevention of Significant Deterioration
(PSD) and New Source Review (NSR) regulations. 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
levels are lower for more seriously polluted areas.
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 Clean Air Act
for six criteria pollutants—sulfur dioxide, particulate matter, nitrogen dioxide, carbon monoxide, ozone, and
lead— to protect the public from toxic emissions to the atmosphere.
New Source Review (NSR) : The NSR and PSD provisions of the CAA strive to ensure that potential new
sources of air pollution (new plants or facilities, or additions to existing ones) take proper steps to minimize
pollution levels. The goals of the NSR program are: 1) to ensure that an increase in emissions due to a new
source or modification to an existing source does not significantly deteriorate air quality; 2) to ensure that
source emissions are consistent with applicable State attainment plans; 3) to ensure that air quality related
values are not negatively impacted in areas that have greater pollution problems; and 4) to establish control
technology requirements that maximize productive capacity while minimizing impacts on air quality.
Nitrogen oxides (NOx): 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.

Vandenberg XL Project                                                                    13-31-99)
  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
  attainment and nonattainment at the same time. It has been estimated that 60% of Americans live in
  nonattainment areas. Based on the severity of the problem, nonattainment areas are classified as marginal,
  moderate, serious, severe, and extreme.
  Non-road engine: A term used in the Clean Air Act to refer to engines on farm and construction equipment,
  gasoline-powered lawn and garden equipment, and powerboats and outboard motors.
  Ozone (O3): Ozone is found in two layers of the atmosphere, the stratosphere and the troposphere. In the
  stratosphere (the atmospheric layer 10 miles or more above the earth's surface) ozone is a natural form of
  oxygen that provides a protective layer shielding the earth from ultraviolet radiation. In the troposphere (the
  layer extending up to 10 miles from the earth's surface), ozone is a major component of photochemical smog.
  It can seriously impair respiratory systems, and i s one of the most widespread of all the criteria pollutants for
  which the CAA required EPA to set standards. Ozone in the troposphere is produced through complex
  chemical reactions of NOx, VOCs, and sunlight.
  Part 70 Sources: Part 70 refers to the regulations promulgated by EPA to implement Title V of the Clean Air
  Act, which are contained in Title 40, Code of Federal Regulations, Part 70. Part 70 Sources are major station-
  ary sources of pollutants that are subj ect to regulation under Title V.
  Precursor: In photochemistry, a compound antecedent to a pollutant. For example, VOCs andNOx often react
  in sunlight to form ozone or other photochemical oxidants. As such, VOCs and NOx are precursors.
  Prevention of Significant Deterioration (PSD): The 1977 amendments to the Clean Air Act established the
  PSD program, designed to help areas maintain their clean air. National policies and guidelines were developed
  for managing economic growth while preventing deterioration of air quality.
  Potential to Emit (PTE):  A source of pollution's total PTE is determined by a two-step process. First, the
  source's potential emissions at maximum physical capacity are establi shed. This is then reduced by any recog-
  nized 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 object 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 rel eased, and what kinds of steps the source's owner or operator i s taking
  to reduce pollution, including plans to monitor the pollution.

  Volatile Organic Compound (VOC): Any organic compound that easily evaporates and participates in atmo-
  spheric photochemical reactions, except those designated by EPA as having negligible photochemical reactivity.