Air Quality Air Quality
Compliance Management Compliance Management for for
Small & Mid-Size Small & Mid-Size
Rural UtilitiesRural Utilities
Air Quality - Permitting / Compliance / Air Quality - Permitting / Compliance / MonitoringMonitoring
Office Locations inOffice Locations inAnchorage, AKAnchorage, AKJuneau, AKJuneau, AKPortland, ORPortland, ORTucson, AZTucson, AZCedar City, UTCedar City, UT
Experience in Experience in (almost 20 years)(almost 20 years)
UtilitiesUtilitiesMining / ConstructionMining / ConstructionOil & Gas / Refining / PipelinesOil & Gas / Refining / PipelinesSeafood Industry / SPCC PlansSeafood Industry / SPCC Plans
Presenter: Presenter: Erik Haas, PrincipalErik Haas, Principal [email protected] / www.hmhconsulting.org / www.hmhconsulting.org
• State/Local Air Quality Rules
• 40 CFR 60 (NSPS), Subparts – Dc: small steam generators– K-Kb: Petroleum Storage Tanks– O: Sewage Treatment Plants– GG: Utility Gas Turbines– E, AAAA-FFFF: Mun. Waste Incineration– IIII: Stationary Diesel Engines
• new engines – establish emission limits by model year 2005 and later
• Emission limits certified by manufacturer or Source Testing (Appendix A)
– JJJJ: Stationary Spark-Ignition Engines– KKKK: Stationary Combustion Turbines– OOOO: Crude Oil/Ntl. Gas
Production/Transmission/Distribution
Small Utilities - AQ Rules & Small Utilities - AQ Rules & Regulations Regulations
• 40 CFR 61 (NESHAP), Subparts E (Mercury), M (Asbestos)
• 40 CFR 63 (NESHAP by source categories), Subparts:– ZZZZ: Stat. Recip. Internal Combustion Engines (RICE)
• Retrofit-Control Equipment
• Existing Engines - Prior to 2002/2006
• Install Oxy-Catalysts
• Performance Testing – (hand-held analyzers) vs. Appendix A:Testing Methods
– JJJJJJ: Indust./Comm./Institut. Boiler Area Sources
• 40 CFR 98 – Mandatory Greenhouse Gas Reporting
Small Utilities - AQ Rules & Small Utilities - AQ Rules & Regulations – contRegulations – cont..
Environmental Management Systems Environmental Management Systems (EMS) for Small/Mid-Size Utilities(EMS) for Small/Mid-Size Utilities
PRINCIPLE: Environmental StewardshipEnvironmental Stewardship
•Full ISO 14001 very comprehensive/expensiveFull ISO 14001 very comprehensive/expensive
•Adapted Structure of ISO 14001Adapted Structure of ISO 14001 Planning Planning DOINGDOING CHECKINGCHECKING ACTING ACTING
“Transition from a knowledge-based and orally-directed compliance management system to a more defined structured and documented management system. “
PLANNINGPLANNING
–STRUCTURE STRUCTURE
• Position Responsibilities
• Accountability
–ESTABLISHESTABLISH ASPECTS, OBJECTIVES AND TARGETS ASPECTS, OBJECTIVES AND TARGETS
• Aspects - primary environmental issues
• Objectives - measurable multi-year goals as indicators for progress
• Targets - yearly measuring stick toward the multi-year Objective
–ESTABLISH ESTABLISH
• SOPs, Work Sheets, Forms, Directives, Quarterly Calendars, etc.
Environmental Management Systems (EMS) for Small/Mid-Size Environmental Management Systems (EMS) for Small/Mid-Size Utilities – cont.Utilities – cont.
• DOINGDOING• EVERYBODY HAS A ROLE IN GETTING THE JOB DONE EVERYBODY HAS A ROLE IN GETTING THE JOB DONE
• IMPROVE SKILLS, KNOWLEDGE & TRAININGIMPROVE SKILLS, KNOWLEDGE & TRAINING
• CHECKINGCHECKING• OPERATIONAL OVERSIGHT OPERATIONAL OVERSIGHT (Facility Foreman/Manager)(Facility Foreman/Manager)
• ENVIRONMENTAL COMPLIANCE VERIFICATION ENVIRONMENTAL COMPLIANCE VERIFICATION (Env. Coord.)(Env. Coord.)
• INDEPENDENT AUDITS OF THE EMS - INDEPENDENT AUDITS OF THE EMS - Independent Contract Firm – other Independent Contract Firm – other than EMS Consultantthan EMS Consultant
• ACTINGACTING Continual ImprovementContinual Improvement
• QUARTERLY REVIEW AND OVERSIGHT QUARTERLY REVIEW AND OVERSIGHT
• THE ANNUAL EMS REVIEW THE ANNUAL EMS REVIEW Re- assessment of Aspects/Targets/ObjectivesRe- assessment of Aspects/Targets/Objectives
• APPROVAL & EXECUTION OF APPROVAL & EXECUTION OF any EMS CHANGES any EMS CHANGES Facility Manager w/ approval by Utility BoardFacility Manager w/ approval by Utility Board
Environmental Management Systems (EMS) for Small/Mid-Size Environmental Management Systems (EMS) for Small/Mid-Size Utilities – cont.Utilities – cont.
Environmental Management Systems (EMS) for Small/Mid-Size UtilitiesEnvironmental Management Systems (EMS) for Small/Mid-Size UtilitiesNome, AKNome, AK
Clean-Coal Project ChallengesClean-Coal Project Challenges
• 50 MW Clean-Coal Project in Healy, AK - Adjacent to Coal Mine 50 MW Clean-Coal Project in Healy, AK - Adjacent to Coal Mine
• At border of Denali Ntl. ParkAt border of Denali Ntl. Park
• TRW Clean-Coal Combustion System/B&W Spray Dryer AbsorberTRW Clean-Coal Combustion System/B&W Spray Dryer Absorber
Healy Clean Coal Project – Course of EventsHealy Clean Coal Project – Course of Events
• Construction from 1995-1997 – cost around $300 million• US-DOE: $120MUS-DOE: $120M• AIDA: $140MAIDA: $140M• AK-Legislature: $25MAK-Legislature: $25M• GVEA/Usibelli Coal: $10MGVEA/Usibelli Coal: $10M
• Met emission limits and performance standards
• Too expensive to operate for GVEA – return to AIDA
• Attempt to remove Clean-Coal Technology – Conv. Technology
• ADEC/EPA agreed to re-issue Air Permit
• Sierra Club files Injunction – Impacts on Denali Ntl. Park
• Year 2000 - Shut down/moth-balled
Challenges with Utility MR&R at Rural Challenges with Utility MR&R at Rural UtilitiesUtilities
– Ever increasing regulatory burdenEver increasing regulatory burden– Monitoring/Recordkeeping/ReportingMonitoring/Recordkeeping/Reporting
• fuel gas from producersfuel gas from producers
• fuel oil deliveriesfuel oil deliveries
• KWhr produced / Internal LossesKWhr produced / Internal Losses
• Transmission Line LossesTransmission Line Losses
• Individual household consumptionsIndividual household consumptions
– Power Cost Equalization Reporting IssuesPower Cost Equalization Reporting Issues• Where does Energy go ? Excessive line Where does Energy go ? Excessive line
losses ???losses ???
• ReportedReported power generation efficiencies way power generation efficiencies way highhigh
• Very low household power consumptionsVery low household power consumptions
Challenges with Utility MR&R at Rural Utilities – Challenges with Utility MR&R at Rural Utilities – Barrow, AKBarrow, AK