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DEPARTMENT OF ENVIRONMENTAL QUALITY 

DIVISION OF AIR QUALITY 

Michael O. Leavill 150Notth 1950WcsI 

Gown= . P.O. Box 144820 

Dianne R. Nielson, Ph.D. Salt Lake City, Utah 84114-4820 

E=wive Oir=Dr (80 I) 536-4000 

Russell A. Robens (801) 536-4099 Fax 

Dir=Dr (801) 538-4414 T.D.D. 

DAQE-068-95 

January 30, 1995 

James R. Van Orman 

Director of Environmental Management 

Headquarters Ogden Air Logistics Center 

Department of the Air Force 

Hill Air Force Base. Utah 84056 

Re: Support Document for Approval Order DAQE-067-95 

Dear Mr. Van Orman: 

This letter is a support document for Approval Order (AO) DAQE-067-95, dated January 30, 1995, 

and it establishes reporting requirements when Hill Air Force Base intends to change 

paint/solvent/thinner used in their painting operations. Hill Air Force Base is permitted to change the 

paint/solvent/thinner used in their painting operations without prior approval from the Division of Air 

Qual ity (DAQ), subject to the following conditions: 

A.	 If Hill Air Force Base intends to increase the rates of emissions of specific noncriteria pollutants and/or change the chemical composition of non-criteria pollutant 

emissions. compared to the emissions listed in the 1993 Base-wide HAPs emissions 

inventory times a scaling factor of 5.43 1

, then Risk Index (defined in D. below) needs 

to be calculated for those compounds that would contribute to the increase in the rates 

of emissions and/or the chemical composition of the emissions. If the calculated Risk 

Index exceeds 21.22 (current high value as per the Notice of Intent (NOl) for this 

AO), a NOl shall he tiled in accordance with Section 3.1, UACR. 

B.	 If the AO is determined to require changes, Hill Air Force Base shall submit as pan 

of the NOI, the proposed rates and chemical composition of the new emissions, and 

screen model ing results to demonstrate that the proposed changes in the amounts 

and/or character of the emissions shall not cause an exceedance of TLV11 00 (for non1A scaling factor of 5.43 is the ratio of the total Base-wide allowable HAP emissions (201.2 

tons per year considering all HAP emissions as VOC emissions) to the total Base-wide HAP 

emissions listed in the 1993 (the latest Base-wide HAPs emissions inventory available before this AO 

was issued), which was reponed as 74.076 pounds per year (37.04 tons per year). 201.2 TPY/37.04 

TPY = 5.43 

4.2.4-413 
DAQE-068-95
 

January 30. 1995
 

Page 2
 

carcinogens) and TL V1300 (for carcinogens). The present Maximum Risk Index of 

21.22 shall then be revised (increased) to rer1ect the proposed change in the amounts 

andlor character of emissions. 

C.	 If Hill Air Force Base intends to change the rates andlor chemical composition of the 

non-criteria pollutant emissions currently approved according to the information 

submitted from the 1993 emissions inventory as a part of the NOI for this AO, and 

determines that a change in the AO is not required because the maximum Risk Index 

of 21.22 is not exceeded by the changes. then Screen modeling is not required to be 

performed and a formal NOI is not required to be tiled. Hill Air Force Base is only 

required to submit to the Executive Secretary a Iist of changes in the chemical 

composition and emission rates. along with the annual HAPs emissions inventory 

submittal. 

D.	 Risk Index shall he cakulated according to the formula given below: 

actual m:lXlln"m pounds of tOXICS cmltted per eight-hour period 

Risk Index =
 

TLV/IOO or TLV/300
 

where. TLV represents the Threshold Limit Value of the chemical compound. ­

TLV11 00 is used in the ahove equation when the chemical con~:lound is not 

.:onsidered to be a carcinogen and TLV/300 is used when the chemical compound is a 

suspected or a contirmed carcinogen. TLV values and the carcinogenicity of chemical 

compounds can be found in a handbook published by the Association of Governmental 

and Industrial Hygienists (Technical Affairs Office, 6500 Glenway Ave., Bldg. D-7, 

Cincinnati. OH 45211-4438). Any other source of TLV values shall be accepted, 

subject to approval by the Executive Secretary. To calculate the actual maximum 

pounds of toxics emitted per eight-hour period (numerator in the Risk Index 

expression). the total scaled-up (to scale up, the proposed emissions are multiplied by 

J factor of 5.43) emissions in pounds per year of the chemical comround after the 

proposed increase is divided by 2.000 hours of oreration per year (assumed at 40 

hours per week ~nd 50 weeks per year). 

If you have any questions or~oncerns. please contact Arjun Ram at (801) 536-4066. 

"I 

Sincerel v.	 .I I I ' . ------.	 . .' f 

I	 

i I I

.

I I ... ! . .~

Russell A. RobertS. Executive Secretary 

--Utah Air Qualitv Board . 

RAR:AR:<.Jn 

cc:	 Davis CUtlnty Health Department
 

EPA RegIOn V[II. Mike Owens
 

4.2.4-414