Data SystemsData Cleanup and SetupBusiness PracticesReports and RecordsAudits
Phase II – Implementation In ProgressEnterprise Environmental Safety and Occupational Health Management Information System (EESOH-MIS)
Conclusions
Ogden Air Logistics Center
BackgroundGeography and Location
Ogden Air Logistics Center
BackgroundAir Requirements Related to Materials
Over 50 of the 90 Conditions in the Hill AFB Title V Permit Require Documentation and Monitoring of Materials
Pollutant Concentration LimitsSulfur, Volatile Organic Compounds, and Hazardous Air Pollutants
Vapor Pressure LimitsMaterial Consumption LimitsTiered Process Controls based on Material and Operation Type
Annual Air Emission Inventory Requires Tracking of Material Throughputs by Process for Over 1,000 Processes
Ogden Air Logistics Center
BackgroundExtensive Documentation Required
Documenting Air Compliance using Material Logs was a Major Task at Hill AFB:
> 500,000 Hazardous Material Issues per Year> 7,000 Different Active Hazardous Materials> 1,400 New Hazardous Materials each Year> 1,000 Processes of Concern for AirNumerous Shop Personnel
Logs Required Entry of Various Parameters Daily by Material
Ogden Air Logistics Center
Project SummarySolution
Process 1
Process 2
Process N
Process 1
Process 2
Process N
Process 1
Process 2
Process N
Local Warehouse 1
Local Warehouse 2
Local Warehouse N
Central Warehouse
Material Ordered
Old Approach:
HM Information Recorded on Logs at each Process by Operator
New Approach:
Use existing data systems instead of logs by adding HM tracking to processes, additional HM characterization, and revised business practices.
Industrial Organizations
Request Material
Hazardous Material Group
Supply Group
Authorized -Yes
Authorized -No
Ogden Air Logistics Center
Project SummaryResults
Existing Data Systems were used to Eliminate Material LogsImproved Material ControlReduced Risk of Non-ComplianceReduce Burden on Organizations
e.g., Aerospace NESHAP Surface Coating Recordkeeping Burden Reduced by 250 hrs per month
Requirements vs. Resources
2000 2001 2002 2003 2004 2005 2006 2007
Requirements
Resources
Ogden Air Logistics Center
Unique Process
Chemical DataMaterial ProductMaterial Issues
Source CategoryParameters
Emission Factors
Define Algorithm
Build Algorithm
Emission UnitsEquipment
StacksTanks
Controls
Regulatory Compliance
Regulatory Documents
Applicable Requirements
ChecklistsInspections
NESHAP
Annual AirEmission Inventory
Compliance
Air Management ToolData ManipulationCustom Reports
Data SystemsAir Program Information Management System
(APIMS)
Ogden Air Logistics Center
Data SystemsHazardous Material Management System
(HMMS)
Hazardous Material Management System (HMMS).
HM information populated from Material Data Safety Sheet (MSDS), Manufacturer, Engineering CalculationsHM issues to Zone and Activities/Processes are recorded.
Ogden Air Logistics Center
Data SystemsLinking APIMS and HMMS
Zone 1
Zone 2
Zone 3
Materials in a Zone are Assigned to Bio
Processes/ Activities
Local Warehouse
Issue
HMMS APIMS
Painting Wing
Cleaning
Sealing parts
Chemical Stripping Unit 1
Degreaser 1
Paint Booth 1
BioProcesses/
Activities are Assigned to Air
Processes
Ogden Air Logistics Center
Data System Cleanup/SetupCharacterize Materials
To demonstrate compliance with air regulations various information must be available for each material.
Material TypeHigh Vapor Pressure Solvent, Top Coat, Primer, Specialty Coating, etc
VOC ContentHAP ContentVapor Pressure
Must be calculated at standard temperature which may vary depending on the rule
Ogden Air Logistics Center
Data System Cleanup/SetupIssue to Process
An evaluation of each process is conducted to determine which materials can be used.
Applicable Air Requirements Based on Process Typee.g., Vapor Degreaser, Aerospace Paint Booth, NSPS Boiler, etc.
Other Applicable Requirementse.g., Bio Engineering, Safety, Occupational Health, Waste, etc.
Material link to process is hard coded in the system.
Ogden Air Logistics Center
Business Practices
Mixed Operations Apply Most Stringent Requirements
e.g., Paint Booths which apply coatings to aerospace and non-aerospace items are subject to aerospace controls at all times during operation.
Only Use Hazardous Materials as Specified in the Authorization Request
As Applied Material Characteristics can be Obtained from HMMS
All Hazardous Materials must be Authorized Before Use and Issues must be Recorded in HMMS
Ogden Air Logistics Center
Records/Reports
Monthly Consumption RecordsCoatingsHigh Vapor Pressure Solvents Other SolventsChemical Stripper Process Type
Annual Air Emission Inventory
Ogden Air Logistics Center
Records/ReportsSolvent Example
Ogden Air Logistics Center
Audits
Audits are Necessary to EnsureMaterial Characterization is CorrectMaterials are Getting to the Correct ProcessBusiness Practices are Followed
Hazardous Materials Group Audits (Existing)~95 HDSCs per Semi-Annual Period
Air Group Audits (New)~900 Processes Annually
Ogden Air Logistics Center
A revolutionary change in doing business:Web-based front-end.Greater exchange of information.More consistent data.Minimizes multiple entries of data.
Status of Implementation at Hill AFBHazardous Materials Complete by End of May 2006Hazardous Waste Proposed to Start in Fall 2006Air Proposed to Start in Late 2007/Early 2008
Phase IIEESOH-MIS
Ogden Air Logistics Center
Phase IIEESOH-MIS Single Integrated System
Air Emission
Waste
MaterialRecycle
Sludge
Vapor Degreaser
Distillation Unit
Air Emissions
Ogden Air Logistics Center
Summary
Phase I - Material Logs EliminatedFocus on Primary MissionCost of Documenting and Maintaining Compliance ReducedReduced the Risk of Non-Compliance
Phase II - EESOH-MIS ImplementationIntegration of Multiple Stove Pipe Data Systems
Air, Water, HazMat, HazWaste, EPCRA, Spills, Industrial Hygiene, Public Health, Ground Safety, etc.
HMMS will be replaced by EESOH-MIS HM by May 2006.
