Managing Air Quality Data 101

Presented by: Chris Bellusci (GeoEngineers) &Claire Lund, PE (Sanborn Head)

International Conference for Environmental Data ManagementMay 14 –15, 2013

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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?

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What are Air Quality Data?

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Data necessary to evaluate or maintain compliance with

air-related regulatory requirements.

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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

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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

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Do you need a Permit?

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Identify Emission Sources

Combustion Devices

Ventilated Process EquipmentDust Collectors

and Baghouses

Spray Guns and Booths

General Fugitive Sources

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Quantify Emissions

Combustion Devices

Ventilated Process EquipmentDust Collectors

and Baghouses

Spray Guns and Booths

General Fugitive Sources

ACTUAL AND

POTENTIAL

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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 Requirementså Operating Dataå Emission Calcså Monitoring Dataå Testing Dataå PM Documents

å Reports

=Air Quality Data

(5 Year Retention)

Boiler

Rating/EmissionLimits

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

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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

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How do you know you are in compliance?

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Compliance Calendar

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How are your air-related data managed?

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How accessible areyour 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.

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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

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What does the future hold for air compliance?

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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: cbellusci@geoengineers.com

Claire G. Lund, PEProject Director Sanborn Head & Associates, Inc.Telephone: 603.415.6144Mobile: 603.340.0945 Email: clund@sanbornhead.com