Slide 1

Report
Managing Air Quality
Data 101
Presented by:
Chris Bellusci (GeoEngineers) &
Claire Lund, PE (Sanborn Head)
International Conference for Environmental Data Management
May 14 –15, 2013
How do your facilities track airrelated compliance issues?
How are your air quality data
currently managed?
How do you know you are in
compliance?
2
What are Air Quality Data?
3
Data necessary to evaluate
or maintain compliance with
air-related regulatory
requirements.
4
Federal Clean Air Act
Passed in 1970, with Major 1990 Amendments
http://officeimg.vo.msecnd.net/en-us/images/MH900149119.jpg
State-level Administrative Code
County or Provincial Regulations
5
 Criteria Pollutants




PM, CO, SOx, NOx, Lead, Ozone (VOCs/NOx)
NAAQSs (2 Levels)
Major/Minor Sources
SIPs  Permits (PSD/NSR)
 Hazardous Air Pollutants




187 “Toxics”
Major/Area Sources
Ambient Air Limits
NESHAPs
 Greenhouse Gases
 Reporting & Recordkeeping
 Tailoring Rule
http://www.epa.gov/oaqps001/greenbk/mappm10.html
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How is Air Quality Regulated?
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Title V CAA – Operating Permits
 Establishes Permit Programs
 Permit Application & Permit Content Requirements
Company A
8
Do you need a Permit?
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Identify Emission Sources
Combustion
Devices
Spray Guns
and Booths
Dust Collectors
and Baghouses
General Fugitive
Sources
Ventilated Process
Equipment
10
Quantify Emissions
Spray Guns
and Booths
Dust Collectors
and Baghouses
ACTUAL
AND
POTENTIAL
General Fugitive
Sources
Combustion
Devices
Ventilated Process
Equipment
11
What is in your permit?
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Permit Contents










Emission Units & Pollution Control Equipment
Conditions - Emission Limitations
Monitoring & Testing
Inspections
Recordkeeping
Reporting
Certification
Fee Payment
Renewals & Shield
Deviation Requirements
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Device & Facility Requirements
Rating/Emission
Limits
Boiler
NESHAP
Fuel Use
Tracking
Hours of
Operation
Maintenance,
Inspections, or
Testing
Materials
Tracking
Operating or
Emission Limits
Process
Device “A”
Control Device
Operations
Hours of Operation
NESHAP
Recordkeeping
& Reporting
 Operating Data
 Emission Calcs
 Monitoring Data
 Testing Data
 PM Documents
 Reports
=
Air Quality Data
(5 Year Retention)
14
What isn’t in your permit?
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Other Air Quality Data Needs
 Demonstration of why your
facility doesn’t need a permit
 Equipment ratings
(e.g., boilers, engines)
 Total facility emissions of
regulated pollutants
 Toxics assessments
 GHG
 Area Source NESHAPs
16
How do you know you
are in compliance?
17
Compliance Calendar
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How are your airrelated data managed?
19
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How accessible are
your data?
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Data Management Goals
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What’s the cost for not
being in compliance?
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The Cost of a Violation
 $215,340 (MA, 2010) – failure to comply with
permit conditions for capture and control of VOCs
 $83,900 (CO, 2010) – failure to conduct inspection
and testing by specified compliance date
 $293,837 (CT, 2009) – failure to comply with RFIs,
monitoring, recordkeeping, and permit conditions
 $81,239 (CA, 2011) – failure to comply with
NESHAP reporting and testing requirements
Information taken directly from the EPA ECHO IDEA database query results.
24
Are you a Target
 Air-Related Inspections:
 Title V’s at least once every 2 years
 Minor/synthetic minors every 5 years
 Other Regulatory Program Inspections
 Were deficiencies found?
 National Enforcement Initiatives
 Mining & Mineral Processing
 Large Industrial Facilities
(e.g., coal-fired power plants, acid plants, cement plants, HAP emitters)
 Natural Gas Extraction
25
What does the future
hold for air compliance?
26
More Confusing and Cumbersome
Regulations
“40 CFR Part 63 Subpart ZZZZ . . . is the most complicated
and confusing regulation in the entire suite of EPA NSPS
and NESHAPS regulations, bar none. We seriously believe
that a viable defense could be mounted against an EPA
enforcement action with the simple but true statement,
'Your honor, we honestly could not discern our
obligation under the rule in a timely manner.‘”
Public comment submitted in response to EPA’s request for public
input on improving regulations per Executive Order 13563
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Contact Information
Chris P. Bellusci
Business Solution Architect
GeoEngineers, Inc.
Telephone: 503.603.6699
Mobile: 541.550.0745
Email:
[email protected]
Claire G. Lund, PE
Project Director
Sanborn Head & Associates, Inc.
Telephone: 603.415.6144
Mobile: 603.340.0945
Email:
[email protected]
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