Compliance and Enforcement Presentation to Industrial Association of Contra Costa County February 22, 2017 Paul Grazzini, Air Quality Specialist Bay Area Air Quality Management District San Francisco, California

Regulating air pollution 9 counties within District Creating rules and regulations Permitting polluting facilities Inspections and enforcement Inspectors are the Boots on the ground. We can write as many rules as we want at the Air District but the agency must have people who are going out everyday into the field, into facilities, making sure they are following the law and keeping their emissions in check. 19,000 permitted sources Five oil refineries Gasoline stations, Dry cleaners & Auto body shops Landfills, paint booths, printers, engines, water treatment plants, etc.

Compliance and Enforcement Compliance & Enforcement Inspection Staff 70 Inspectors Geographic areas Specialty Groups: Refinery, Gas Stations, Dry Cleaning & Auto Body Facilities, Asbestos Projects and Air Toxics In the Compliance and Enforcement Division, there are 70 field staff. Inspectors interpret and apply the various regulations, learn procedures for sampling and monitoring, read smoke plumes with our eyes, go through safety training procedures for being around hazardous materials or dangerous operations. Then we spend our days applying those skills to all sorts of situations. We also have inspectors assigned to specialty groups, where they become experts in specific regulations and operations.

Inspections: Records Audit Compliance & Enforcement Inspections: Records Audit Permit Review Is the permit current or expired? Are source/abatement descriptions accurate? Are there any unpermitted sources? Diesel

Inspections: Records Audit (cont.) Records Review Check for compliance with permit conditions and limits Check for compliance with applicable District / State / Federal Regulations Check that required notifications have been made Diesel

Inspections: Source Audit Compliance & Enforcement Inspections: Source Audit Permit Accuracy What types of materials are being used or made on site? Does the source match what is described on the permit? Is the source equipped and operating as required by permit conditions and regulations? How do we answer those questions? A physical inspection of equipment might include: Looking for leaks of liquid or gases, Checking equipment for signs of problems, misuse or lack of maintenance, Making sure temperatures or pressures are set appropriately for the operation or abatement device Inspecting tanks/containers/labels to find out what types of materials are being used or made on site Looking for visible emissions (dust, smoke, particles) Reviewing Records: Our rules often require a lot of record-keeping and monitoring by facilities. We set limits on how much material they can use (like paints, solvents, gasoline) or how much emissions they are allowed (continuous emissions monitors or source testing). Diesel

Inspections: Source Audit Compliance & Enforcement Inspections: Source Audit Source / Equipment Operation Does the source appear to be in good operating condition / properly maintained? Is the source leaking liquids or gases or emitting dust / odors? Are there any unpermitted sources? How do we answer those questions? A phsyical inspection of equipment might include: Looking for leaks of liquid or gases, Checking equipment for signs of problems, misuse or lack of maintenance, Making sure temperatures or pressures are set appropriately for the operation or abatement device Inspecting tanks/containers/labels to find out what types of materials are being used or made on site Looking for visible emissions (dust, smoke, particles) Reviewing Records: Our rules often require a lot of record-keeping and monitoring by facilities. We set limits on how much material they can use (like paints, solvents, gasoline) or how much emissions they are allowed (continuous emissions monitors or source testing).

Compliance & Enforcement Compliance Read and Understand your permit and applicable regulations Contact BAAQMD with any questions Maintain permit, sources and records Train your staff Plan ahead for change (operations & regulatory) Diesel

Compliance & Enforcement Upcoming Rule Regulation 11, Rule 18: Reduction of Risk from Air Toxic Emissions at Existing Facilities: Draft rule is geared to reduce toxic emissions from facilities ranging in size from large-scale plants to smaller operations like back-up generators and gas stations.  Diesel

Questions or Comments: Paul Grazzini Air Quality Specialist Bay Area Air Quality Management District pgrazzini@baaqmd.gov (415)749-4783 Diesel