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Air Permit Compliance for Dummies

Air Permit Compliance for Dummies. Presented by Claire Booth, E.I. Motivation. Positive Job Well Done Personal Performance Objectives Promotion / Career Growth Paycheck. Motivation. Negative Fines - $10k to $25k per day Negative PR Criminal penalties. Recent Compliance Actions.

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Air Permit Compliance for Dummies

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  1. Air Permit Compliance for Dummies Presented by Claire Booth, E.I.

  2. Motivation • Positive • Job Well Done • Personal Performance Objectives • Promotion / Career Growth • Paycheck

  3. Motivation • Negative • Fines - $10k to $25k per day • Negative PR • Criminal penalties

  4. Recent Compliance Actions • EPA vs. du Pont – July 20, 2007 • $4.1 million penalty • 4 SAPs (KY, LA, OH, VA) • Failure to comply with NSPS • CITGO – trial July 9, 2007 • Guilty of felony criminal violations • 2 tanks without proper controls • Possible fines up to $500,000 per count and 5 years probation

  5. Tip Number 10 • Work Smarter – Not Harder • Simplify the process • Automate & distribute data management systems • Capture data from the source • Data loggers • Laboratory electronic deliverables

  6. Tip Number 9 • Read the Permit(s) • Specific Conditions • General Conditions • How often reviewed? • Strict Interpretations • Units of measure • Regulatory Citations • How often reviewed?

  7. Tip Number 8 • Check • Double check • Internal cross check • External review

  8. Tip Number 7 • Implement Warning Systems • Know your limits • Put limits on report(s) • Green / yellow / red • Trend analysis • Missing data / deadline notifications • E-mail tree • Pager • Auto-dialer

  9. Tip Number 6 • Calendaring • What tasks when • Recurring • Lead time • Notification • Acknowledgement • Completion • High importance if not complete

  10. Tip Number 5 • Develop Relationships • Internal • Management • Facilities/Maintenance • Production Staff • External • Regulatory Agencies • Local Businesses • Industry Groups

  11. Tip Number 4 • Management of Change • The only thing constant is change • Jack Welch Quotes • Equipment / Facilities / Properties • Easier to include in original construction than to retrofit • Staff • Promotion • Growth

  12. Tip Number 4 • Regulatory Updates • Boiler MACT officially vacated – July 30, 2007 • NSPS for ICE – Subpart IIII (generators) • Proposed NSPS and amendments - Subpart J and Ja (petroleum refineries) • ULSD

  13. Tip Number 3 • Documentation / “Paper Trail” • Include in files summaries of activities • Data management strategy • What to print • What to archive • How to backup • Regulatory correspondence • Periodic file reviews • Do not rely on verbal agreements

  14. Tip Number 2 • Written Procedures / Instructions • ISO 14000 like • Transition (lottery) • Coverage (vacation / illness)

  15. Tip Number 2 • Written Procedures / Instructions • ISO 14000 like • Documents how the particular tasks are performed • AOR documentation • Annual compliance report • Continuity Binder • Document a full month of compliance procedures • Show all calculations • Process flow diagrams

  16. Tip Number 1 • Know Thy Process and Regulations • Process knowledge is KEY • Regulatory applicability • Basis for specific permit conditions • May contain requirements not included in your permit • May offer opportunities for streamlining / permit hygiene

  17. Questions? Compliance guru: Mitchell Hait mhait@golder.com (904) 363-3430

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