Managing Air Quality
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
How do you know you are in
What are Air Quality Data?
Data necessary to evaluate
or maintain compliance with
Federal Clean Air Act
Passed in 1970, with Major 1990 Amendments
State-level Administrative Code
County or Provincial Regulations
PM, CO, SOx, NOx, Lead, Ozone (VOCs/NOx)
NAAQSs (2 Levels)
SIPs Permits (PSD/NSR)
Hazardous Air Pollutants
Ambient Air Limits
Reporting & Recordkeeping
How is Air Quality Regulated?
Title V CAA – Operating Permits
Establishes Permit Programs
Permit Application & Permit Content Requirements
Do you need a Permit?
Identify Emission Sources
What is in your permit?
Emission Units & Pollution Control Equipment
Conditions - Emission Limitations
Monitoring & Testing
Renewals & Shield
Device & Facility Requirements
Hours of Operation
Air Quality Data
(5 Year Retention)
What isn’t in your permit?
Other Air Quality Data Needs
Demonstration of why your
facility doesn’t need a permit
(e.g., boilers, engines)
Total facility emissions of
Area Source NESHAPs
How do you know you
are in compliance?
How are your airrelated data managed?
How accessible are
Data Management Goals
What’s the cost for not
being in compliance?
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.
Are you a Target
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
What does the future
hold for air compliance?
More Confusing and Cumbersome
“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
Chris P. Bellusci
Business Solution Architect
Claire G. Lund, PE
Sanborn Head & Associates, Inc.