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Managing Air Quality Data 101
Presented by: Chris Bellusci (SmartMine@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 are your air-related data managed?
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How accessible areyour data?
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Data Management Goals
Data Availability Data Management Data Retention Consistent & Timing
Reporting Getting the right data to
the right people
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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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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 Client Solutions SmartMine@GeoEngineers, Inc. Telephone: 503.603.6699 Mobile: 541.550.0745 Email: [email protected]
Claire G. Lund, PEProject Director Sanborn Head & Associates, Inc.Telephone: 603.415.6144Mobile: 603.340.0945 Email: [email protected]