From: To: Subject: Date: (b) (6) (b) (6) RE: Air regulatory requirements for DHS support (UNCLASSIFIED) Tuesday, July 3, 2018 4:23:00 PM (b) (6) Can you please spell the acronyms? Respectfully, (b) (6) Supervisory Environmental Engineer Division Chief, Environmental Division Directorate of Public Works Building 624, Room 116A 1733 Pleasonton Rd. USAG Fort Bliss, TX 79916 (b) (6) We are the Army's Home.  Learn more at www.imcom.army.mil • IF THIS EMAIL CONTAINS INFORMATION SUBJECT TO THE PRIVACY ACT, FREEDOM OF INFORMATION ACT, OR CONTAINING PII: - ATTENTION: The information contained in this communication and any accompanying attachments is intended for the sole use of the names addresses/recipients to whom it is addressed in their in conduct of official business of the United States Government. This communication may contain information that is exempt from disclosure under the Freedom of Information Act, 5 U.S.C. 552 and the Privacy Act, 5 U.S.C. 552a. Addressees/recipients are not to disseminate this communication to individuals other than those who have an official need to know the information in the course of their official government duties. If you received this communication in error, any disclosure, coping, distribution, or the taking of any action on this information is prohibited. If you received this confidential electronic mailing in error, please notify the sender by a “reply to the sender only: message, delete the email immediately and destroy all electronic and hard copies of the communication, including attachments. • FOR ALL OTHER EMAILS: - ATTENTION: The email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. -----Original Message----From: (b) (6) Sent: Tuesday, July 03, 2018 11:06 AM To: (b) (6) Subject: FW: Air regulatory requirements for DHS support (UNCLASSIFIED) 11/30/2018 023445 CLASSIFICATION: UNCLASSIFIED Hi (b) (6) go with this inf... As per our conversation yesterday: 1) Using generators  ( INTERNAL COMBUSTION RECIPROCATING ENGINES)in the camp will not require any registration or trigger any regulatory air requirements  since they will be considered a mobile source as per 40 CFR Part 1068 . EPA would consider a portable engine stationary and subject to the NSPS-NESHAP if it: 1.) Remains at the same location for more than 12 consecutive months. 2) If the plan is to have them longer than a year than authorization as per 40 CFR part 60 subpart iiii  (4207) will be needed.         The possible authorizations would be                                 a) PBR 106.512. This will take approx. 30 days                                 b) Standard permit PI-S (Electric Generating Unit Standard Permit ) or                                 b) PI-1 case-by-case permit. This  will take a year or more **however, without knowing the size and number of units, it is not possible to know which authorization would work. ***The tricky part is, if you go under the assumption that they will be present for less than a year, but you determine sometime down the road during that year period that they will be needed longer than a year, then at that point, you would have to stop operating and get the correct authorization, which could take 30 days or so at the short end if the PBR would work, and a year or more if a PI-1 is needed. Thank you (b) (6) Air & Waste Water Program Manager Directorate of Public Works Environmental Division/Compliance Branch Building 622, Office 104 Bldg 622, Taylor Road USAG Fort Bliss, TX 79916 (b) (6)                            We are the Army's Home Learn more at www.imcom.army.mil • IF THIS EMAIL CONTAINS INFORMATION SUBJECT TO THE PRIVACY ACT, FREEDOM OF INFORMATION ACT, OR CONTAINING PII: - ATTENTION: The information contained in this communication and any accompanying attachments is intended for the sole use of the names addresses/recipients to whom it is addressed in their in conduct of official business of the United States Government. This communication may contain information that is exempt from disclosure under the Freedom of Information Act, 5 U.S.C. 552 and the Privacy Act, 5 U.S.C. 552a. Addressees/recipients are not to disseminate this communication to individuals other than those who have an official need to know the information in the course of their official government duties. If you received this  communication in error, any disclosure, coping, distribution, or the taking of any action on this information is prohibited. If you received this confidential electronic mailing in error, please notify the sender by a “reply to the sender only: message, delete the email immediately and destroy all electronic and hard copies of the communication, including attachments. -----Original Message----From: (b) (6) Sent: Tuesday, July 3, 2018 10:56 AM To: (b) (6) 11/30/2018 023446 Cc: (b) (6) Subject: RE: Air regulatory requirements for DHS support (UNCLASSIFIED) CLASSIFICATION: UNCLASSIFIED (b) (6) As per our conversation yesterday: 1) Using generators  ( INTERNAL COMBUSTION RECIPROCATING ENGINES)in the camp will not require any registration or trigger any regulatory air requirements  since they will be considered a mobile source as per 40 CFR Part 1068 . EPA would consider a portable engine stationary and subject to the NSPS-NESHAP if it: 1.) Remains at the same location for more than 12 consecutive months. 2) If the plan is to have them longer than a year than authorization as per 40 CFR part 60 subpart iiii  (4207) will be needed.         The possible authorizations would be                                 a) PBR 106.512. This will take approx. 30 days                                 b) Standard permit PI-S (Electric Generating Unit Standard Permit ) or                                 b) PI-1 case-by-case permit. This  will take a year or more **however, without knowing the size and number of units, it is not possible to know which authorization would work. ***The tricky part is, if you go under the assumption that they will be present for less than a year, but you determine sometime down the road during that year period that they will be needed longer than a year, then at that point, you would have to stop operating and get the correct authorization, which could take 30 days or so at the short end if the PBR would work, and a year or more if a PI-1 is needed. Thank you (b) (6) Air & Waste Water Program Manager Directorate of Public Works Environmental Division/Compliance Branch Building 622, Office 104 Bldg 622, Taylor Road USAG Fort Bliss, TX 79916 (b) (6)                            We are the Army's Home Learn more at www.imcom.army.mil • IF THIS EMAIL CONTAINS INFORMATION SUBJECT TO THE PRIVACY ACT, FREEDOM OF INFORMATION ACT, OR CONTAINING PII: - ATTENTION: The information contained in this communication and any accompanying attachments is intended for the sole use of the names addresses/recipients to whom it is addressed in their in conduct of official business of the United States Government. This communication may contain information that is exempt from disclosure under the Freedom of Information Act, 5 U.S.C. 552 and the Privacy Act, 5 U.S.C. 552a. Addressees/recipients are not to disseminate this communication to individuals other than those who have an official need to know the information in the course of their official government duties. If you received this  communication in error, any disclosure, coping, distribution, or the taking of any action on this information is prohibited. If you received this confidential electronic mailing in error, please notify the sender by a “reply to the sender only: message, delete the email immediately and destroy all electronic and hard copies of the communication, including attachments. CLASSIFICATION: UNCLASSIFIED CLASSIFICATION: UNCLASSIFIED 11/30/2018 023447