managing air quality data 101
DESCRIPTION
Presented by: Chris Bellusci ( GeoEngineers ) & Claire Lund, PE (Sanborn Head) International Conference for Environmental Data Management May 14 –15, 2013. Managing Air Quality Data 101. How do your facilities track air-related compliance issues? - PowerPoint PPT PresentationTRANSCRIPT
Managing Air Quality Data 101
Presented by: Chris Bellusci (GeoEngineers) &Claire Lund, PE (Sanborn Head)
International Conference for Environmental Data ManagementMay 14 –15, 2013
2
How do your facilities track air-related compliance issues?
How are your air quality data currently managed?
How do you know you are in compliance?
3
What are Air Quality Data?
4
Data necessary to evaluate or maintain compliance with
air-related regulatory requirements.
5
Federal Clean Air ActPassed in 1970, with Major 1990 Amendments
State-level Administrative Code
County or Provincial Regulations
http://officeimg.vo.msecnd.net/en-us/images/MH900149119.jpg
6
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
7
How is Air Quality Regulated?
8
Title V CAA – Operating Permits Establishes Permit Programs Permit Application & Permit Content Requirements
Company A
9
Do you need a Permit?
10
Identify Emission Sources
Combustion Devices
Ventilated Process EquipmentDust Collectors
and Baghouses
Spray Guns and Booths
General Fugitive Sources
11
Quantify Emissions
Combustion Devices
Ventilated Process EquipmentDust Collectors
and Baghouses
Spray Guns and Booths
General Fugitive Sources
ACTUAL AND
POTENTIAL
12
What is in your permit?
13
Permit Contents Emission Units & Pollution Control Equipment Conditions - Emission Limitations Monitoring & Testing Inspections Recordkeeping Reporting Certification Fee Payment Renewals & Shield Deviation Requirements
14
Device & Facility Requirementså Operating Dataå Emission Calcså Monitoring Data
å Testing Dataå PM Documents
å Reports
=Air Quality Data
(5 Year Retention)
Boiler
Rating/Emission
Limits
Fuel Use Tracking
Hours of Operation
NESHAPMaintenance,
Inspections, or Testing
Process Device “A”
Operating orEmission Limits
MaterialsTracking
Control Device Operations
Hours of Operation
NESHAPRecordkeeping
& Reporting
15
What isn’t in your permit?
16
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
17
How do you know you are in compliance?
18
Compliance Calendar
19
How are your air-related data managed?
20
21
How accessible areyour data?
22
Data Management Goals
23
What’s the cost for not being in compliance?
24
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.
25
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
26
What does the future hold for air compliance?
27
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
28
Contact Information
Chris P. Bellusci Business Solution Architect GeoEngineers, Inc. Telephone: 503.603.6699 Mobile: 541.550.0745 Email: [email protected]
Claire G. Lund, PEProject Director Sanborn Head & Associates, Inc.Telephone: 603.415.6144Mobile: 603.340.0945 Email: [email protected]