Transcript Slide 1
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 6 How is Air Quality Regulated? 7 Title V CAA – Operating Permits Establishes Permit Programs Permit Application & Permit Content Requirements Company A 8 Do you need a Permit? 9 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? 12 Permit Contents Emission Units & Pollution Control Equipment Conditions - Emission Limitations Monitoring & Testing Inspections Recordkeeping Reporting Certification Fee Payment Renewals & Shield Deviation Requirements 13 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? 15 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 18 How are your airrelated data managed? 19 20 How accessible are your data? 21 Data Management Goals 22 What’s the cost for not being in compliance? 23 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 27 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] 28