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Clean Air Act Implementation Through an Environmental Management System

This article discusses the implementation of the Clean Air Act through the use of an Environmental Management System (EMS) at a depot. It covers the existing compliance activities, integration of existing systems, and the benefits of using an EMS. The article also provides an overview of what an EMS is, the US Army EMS Implementation Guide, and the progress made in addressing CAA compliance at the depot.

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Clean Air Act Implementation Through an Environmental Management System

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  1. Clean Air Act Implementation Through an Environmental Management System April 2004

  2. CAA Implementation Throughan EMS - Background • Increased Production Stemming from National Security Initiatives • Depot Wide Implementation of an ISO 14001 Certified EMS • December 2003 Issuance of the Depot’s First CAA Title V Permit

  3. CAA Implementation - The Big Picture

  4. CAA Implementation • Existing CAA Compliance Activities in Place • Addressed NESHAP, NSPS, and existing permit provisions • Existing GIS and Web-based Systems for Managing Data • Depot’s Existing Air Permits Replaced by Title V Permit • Issued December 2003 • 149 pages • Contains MRRs (monitoring, recordkeeping, and reporting) requirements for air emission sources • Includes annual certification requirements • Federally enforceable legal document

  5. CAA Implementation (cont.) • The New CAA Title V Compliance Approach Integrates Existing Systems • Existing CAA Compliance Activities • Existing GIS and web-based systems • Depot’s New EMS • Depot’s New EMS Became the Framework for Integration

  6. What is an EMS? Environmental Policy • Planning • Environmental Aspects • Legal & Other • Objectives and Targets • Env. Mgmt. Programs Management Review • Checking & Corrective Action • Monitoring & Measurement • Non-Conformance/ Corrective & Preventive Action • Records • EMS Audits • Implementation • & Operation • Structure and Responsibility • Training, Awareness & Competence • Communication • Document Control • EMS Documentation • Operational Control • Emergency Preparedness & Response

  7. What is an EMS? US Army EMS Implementation Guide Definition: • Management system that integrates environmental concerns and issues into the organization’s overall management process • Addresses organizational structure, and resources for developing, achieving, implementing, and maintaining the environmental policy • Enables an organization of any size or type to control the impact it has on the natural environment • Allows an organization to achieve and maintain compliance with the current environmental requirements

  8. Benefits with EMS • Improved environmental performance • Reduced costs • Improved compliance • Improved process efficiency • Improved confidence in the overall program • Fewer overlaps and gaps between programs • Maximize use of existing capabilities • Proactive vs. reactive • EMS implementation across DoD

  9. CAA Implementation Through an EMS • Established Depot-Wide Procedures to Address CAA Compliance • New Source Standard Operating Procedures (SOP) • Title V Compliance Procedures • Depot Staff Trained on the Procedures • Implemented Procedures • Checked and Verified Progress

  10. Depot-Wide Procedures to Address CAA Compliance • New Source SOP • Procedure established for notifying the Air Team of projects • New emission sources identified early • Modifications to existing equipment/operations delineated prior to implementation and permitting • Decommissioning of emission sources properly documented and credits established

  11. Depot-Wide Procedures to Address CAA Compliance (cont.) • New Source SOP • Includes elements to account for: • Schedules/timeframes • Documentation and permitting requirements • Specifications for control equipment • Depot approvals and notification requirements • Uses ANAD’s existing web-based system

  12. Depot-Wide Procedures to Address CAA Compliance (cont.) • Title V Compliance Procedures • Gap analysis performed on ANAD’scurrent CAA compliance procedures • Data collection • Source monitoring • Documentation • Defined MRR requirements of the permit • Developed procedures for each operation regulated by the permit • Recordkeeping forms • Compliance report forms to submit to the State

  13. Staff Training and Implementation • Developed Training Materials • Permit overview and background information • Operator procedures • Recordkeeping forms • Conducted 5 Days of Training • Shop by shop • Specific to each operations/emission source • Supervisors and operators

  14. Checked and VerifiedProgress • Developed Inspection Checklist • Operator procedures • MRR requirements • Conducted 3 Days of Inspections at the Depot • Verified operators were correctly following procedures • Identified gaps in compliance activities • Informed Operators of Gaps and Reinforced Procedures • Ongoing “Spot Checks”

  15. State Title V Audit in February 2004 Resulted in No Findings!

  16. Conclusion • Quickly Responded to New CAA Compliance Requirements • Compliance approach built on existing systems • Implemented Procedures to Engage Appropriate Personnel • Multiple Directorates for new and modified sources • Operators for ongoing MRR compliance activities • Clear Accountability • Rapid and Efficient CAA Compliance Demonstrated

  17. Questions?

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