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

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

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 6

7 How is Air Quality Regulated?

Title V CAA – Operating Permits Establishes Permit Programs Permit Application & Permit Content Requirements 8 Company A

9 Do you need a Permit?

10 Identify Emission Sources Combustion Devices Ventilated Process Equipment Dust Collectors and Baghouses Spray Guns and Booths General Fugitive Sources

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

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) Boiler Rating/Emission Limits Fuel Use Tracking Hours of Operation NESHAP Maintenance, Inspections, or Testing Process Device A Operating or Emission Limits Materials Tracking Control Device Operations Hours of OperationNESHAP Recordkeeping & Reporting

15 What isnt in your permit?

16 Other Air Quality Data Needs Demonstration of why your facility doesnt 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

21 How accessible are your data?

22 Data Management Goals

23 Whats the cost for not being in compliance?

24 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.

25 Are you a Target Air-Related Inspections: Title Vs 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

26 What does the future hold for air compliance?

27 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 EPAs request for public input on improving regulations per Executive Order 13563

28 Contact Information Chris P. Bellusci Business Solution Architect GeoEngineers, Inc. Telephone: Mobile: Claire G. Lund, PE Project Director Sanborn Head & Associates, Inc. Telephone: Mobile: