Managing Air Quality Data 101 Presented by: Chris Bellusci & 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 isn’t in your permit?

16 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

17 How are your air- related data managed?

18

19 How accessible are your data?

20 Data Management Goals  Data Availability  Data Management  Data Retention  Consistent & Timing Reporting  Getting the right data to the right people

21 What’s the cost for not being in compliance?

22 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.

23 What does the future hold for air compliance?

24 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

25 Contact Information Chris P. Bellusci Client Solutions Inc. Telephone: Mobile: Claire G. Lund, PE Project Director Sanborn Head & Associates, Inc. Telephone: Mobile: