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Managing Air Quality Data 101

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?

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Managing Air Quality Data 101

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  1. Presented by: Chris Bellusci (GeoEngineers) & Claire Lund, PE (Sanborn Head) International Conference for Environmental Data ManagementMay 14 –15, 2013 Managing Air Quality Data 101

  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 Act Passed 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 Spray Guns and Booths Ventilated Process Equipment Dust Collectors and Baghouses General Fugitive Sources

  11. Quantify Emissions ACTUAL ANDPOTENTIAL Combustion Devices Spray Guns and Booths Ventilated Process Equipment Dust Collectors and Baghouses General Fugitive Sources

  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 Requirements • Operating Data • Emission Calcs • Monitoring Data • Testing Data • PM Documents • Reports = Air Quality Data (5 Year Retention)

  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. How accessible are your data?

  21. Data Management Goals

  22. What’s the cost for not being in compliance?

  23. $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. The Cost of a Violation

  24. 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

  25. What does the future hold for air compliance?

  26. 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

  27. Contact Information • Claire G. Lund, PEProject Director Sanborn Head & Associates, Inc.Telephone: 603.415.6144Mobile: 603.340.0945 Email:clund@sanbornhead.com Chris P. Bellusci Business Solution Architect GeoEngineers, Inc.Telephone: 503.603.6699 Mobile: 541.550.0745 Email:cbellusci@geoengineers.com

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