Letterkenny pays DEP $14,000 in back fees for VOC emissions
(Chambersburg) — Letterkenny Army Depot has been using three paint-stripping tanks for at least 30 years without a required air quality permit from the state.
The Pennsylvania Department of Environmental Protection apparently never knew the tanks had emissions until 2 years ago.
DEP spokesman John Repetz said state inspectors would check permitted sources at the depot, and Letterkenny personnel were not aware that the material in the unpermitted tanks was high in volatile organics and so did not report them.
To correct matters, Letterkenny has applied to DEP “for the construction of three existing and previously unreported paint stripping tanks.”
Letterkenny provided DEP with data for the tanks’ emissions in prior years and paid the corresponding air emission fees, according to Janet Gardner, spokeswoman for Letterkenny Army Depot.
Repetz said on Monday that Letterkenny paid $14,835 in back fees after the tanks were reported.
Pennsylvania in 1994 established air emissions fees to pay for the air emissions monitoring program. A facility currently pays $85 per ton of pollutant.
Gardner declined to answer questions about how the unreported tanks were discovered.
DEP’s Environment Facility Application Compliance Tracking System lists nine violations from a May 2013 administrative review at Letterkenny. eFACTS tracks environmental permits and compliance throughout Pennsylvania. The violation notices issued to Letterkenny included not having an air quality plan or permits and failing to pay emissions fees.
It’s unclear what regulators will do. The U.S. Environmental Protection Agency will handle any enforcement action because Letterkenny is a federal installation, according to Repetz.
“EPA is aware of the situation regarding Letterkenny Army Depot, and we are looking into it,” said Roy Seneca, a regional EPA spokesman.
Letterkenny and its tenants and contractors comprise the largest employed in Franklin County. The work includes repairing missile systems and mine-resistant ambush-protected vehicles. Paint is stripped from old vehicles and equipment , which is then repainted.
VOCs vapors may have short- and long-term adverse health effects, according to the EPA. Depending on the chemicals, a specific VOC may be highly toxic or have no known health effect.
None of the VOCs from the tanks are on EPA’s Hazardous Air Pollutant list, according to Lindsay.
DEP has given preliminary approval to Letterkenny’s plan to deal with VOCs from the three tanks. Letterkenny does not need to add any control equipment to meet either the best available technology or reasonably available controls required in the plan, according to Repetz.
Letterkenny always follows requirements identified in the Best Available Technology and Reasonably Available Control Technology analyses and other work practices to minimize VOC emissions, according to Gardner.
Letterkenny has other operations that are monitored for VOCs and most recently revised its plan to DEP in 2013.
“We continue to track usage and report emissions on our annual Air Emissions Inventory Report,” Gardner said.
The vapors from the three unreported tanks account for about 20 to 30 percent of the total VOC emissions at the Letterkenny, according to Repetz.
Building 350 contains one paint-stripping tank, originally installed in 1971 and most recently replaced in 2003, according to Lindsay. Building 370 contains two tanks, both installed in 1985. All tanks have secondary containment in case of a spill or leak.
The tanks formerly contained a product from Turco, and currently a Eurostrip product mixture, both of which are paint stripping chemicals that emit VOCs during use, Gardner said.
Together the three tanks are expected to emit in a year nearly 30 tons of VOCs, a ton of sulfur oxides and less than a ton each of nitrogen oxides, carbon monoxide, dust and hazardous air pollutants, according to the permit application. DEP will hold a public hearing about Letterkenny’s application for an operating permit for the tanks. The hearing will be held at 9 a.m. on July 13 at the DEP Southcentral Regional Office, 909 Elmerton Avenue, Harrisburg.
Copies of the application, DEP’s analysis and other documents can be seen at the DEP regional office.
People wishing to speak at the hearing should contact Mr. Gary Helsel, P.E., Acting New Source Review Chief, Southcentral Regional Office, at 814-949-7935, no later than July 6. Oral testimony which has not been pre-scheduled will not be accepted at the hearing. Commenters are asked to provide two written copies of their remarks at the hearing. Oral testimony will be limited to ten minutes per person. Organizations are requested to designate a representative to speak on their behalf.
Written comments may be submitted to the Air Quality Program, 909 Elmerton Avenue, Harrisburg, PA 17110-8200, no later than July 23. Written comments must contain the permit number (28-05002M) and the commenter’s name, address and telephone number.
Jim Hook can be reached at 717-262-4759.
This article comes to us through a partnership between Public Opinion Online and WITF.
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