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Targeting Tools

Targeting Tools. United States Environmental Protection Agency Office of Enforcement and Compliance Monitoring Air Enforcement Division. Desktop Analyses. Publicly-Available Databases Acid Rain; ECHO (HPV) – Watchlist also available to the states/locals; Toxic Reduction Inventory (TRI);

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Targeting Tools

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  1. Targeting Tools United States Environmental Protection Agency Office of Enforcement and Compliance Monitoring Air Enforcement Division

  2. Desktop Analyses • Publicly-Available Databases • Acid Rain; • ECHO (HPV) – Watchlist also available to the states/locals; • Toxic Reduction Inventory (TRI); • Excess Emissions Reports; • Permit information and data; and • Citizens’ notices, petitions, tips and complaints.

  3. Acid Rain Database Reports • Hourly Emission Data • Monthly, Quarterly, Annual Emissions Data • Nitrogen Oxides • Sulfur Dioxide • Opacity

  4. Acid Rain Database • Heat input analysis of Utilities

  5. Acid Rain Database • Heat input analysis of Utilities

  6. Acid Rain Database • Heat input analysis of Utilities

  7. Use of Self-Certified CEMS Data • Identify and track trends related to: • Excess emissions, and • CEMS downtime; • Categorize and investigate data outliers; and • Identify apparent root cause(s) (e.g., SSM).

  8. Review of CEMS Data • Regions are reviewing CEMS data provided by its states; • CEMS data show most sectors are able to achieve, and in fact are, in continuous compliance with emission limitations (opacity too); • Data can be arrayed to prioritize outlying, non-complying sources.

  9. Non-compliance Identified • Typically, multiple quarters of excess emissions at individual facilities; • Control devices not operated or inadequately designed; and • Poor operation and maintenance practices of emissions controls and monitoring systems

  10. Enforcement Results • Seven Notices of Violation and Findings of Violation (NOVs/FOVs) issued since May, 2006 [several more in the pipeline]; • Ongoing discussions to resolve alleged violations with each facility; and • Possible judicial actions.

  11. Goals of CEMS project • Achieve permanent, consistent and continuous compliance; • Level the playing field; • Increase transparency; • Focus on fixing the underlying causes of the excess emissions/CEMS downtime; and • Injunctive relief such as upgrading or installing new controls

  12. Citizen-Generated Information • OECA is committed to meaningfully engaging citizens: • Not our competition; and • Very good source of information. • Targeting information • Petitions; • Notices; and • Targeting. • Tips and complaints

  13. Title 5 Certifications/Petitions • Review of Title 5 certifications and petitions; • Where enforcement actions taken for requirement that was not reported in annual certification a Title V claim should also be plead; and • Selective reviews of Title 5 certifications at problematic sources

  14. Cross-Reference of Emission Inventories Information • Otis – • Tracks emissions through integration of TRI data. • Review of Air Quality Monitors • TRI • There are some problems with TRI • Emission Inventories for State Fees • Can also provide additional violations • Emission Factors may under-estimate emissions (Test Orders)

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