Targeting Tools United States Environmental Protection Agency Office of Enforcement and Compliance Monitoring Air Enforcement Division

Desktop Analyses  Publicly-Available Databases –Acid Rain; –ECHO (HPV) – Watchlist also available to the states/locals; –Toxic Reduction Inventory (TRI); –Excess Emissions Reports; –Permit information and data; and –Citizens’ notices, petitions, tips and complaints.

Acid Rain Database Reports  Hourly Emission Data  Monthly, Quarterly, Annual Emissions Data –Nitrogen Oxides –Sulfur Dioxide –Opacity

Acid Rain Database  Heat input analysis of Utilities

Acid Rain Database  Heat input analysis of Utilities

Acid Rain Database  Heat input analysis of Utilities

Use of Self-Certified CEMS Data  Identify and track trends related to: –Excess emissions, and –CEMS downtime;  Categorize and investigate data outliers; and  Identify apparent root cause(s) (e.g., SSM).

Review of CEMS Data  Regions are reviewing CEMS data provided by its states;  CEMS data show most sectors are able to achieve, and in fact are, in continuous compliance with emission limitations (opacity too);  Data can be arrayed to prioritize outlying, non- complying sources.

Non-compliance Identified  Typically, multiple quarters of excess emissions at individual facilities;  Control devices not operated or inadequately designed; and  Poor operation and maintenance practices of emissions controls and monitoring systems

Enforcement Results  Seven Notices of Violation and Findings of Violation (NOVs/FOVs) issued since May, 2006 [several more in the pipeline];  Ongoing discussions to resolve alleged violations with each facility; and  Possible judicial actions.

Goals of CEMS project  Achieve permanent, consistent and continuous compliance;  Level the playing field;  Increase transparency;  Focus on fixing the underlying causes of the excess emissions/CEMS downtime; and  Injunctive relief such as upgrading or installing new controls

Citizen-Generated Information  OECA is committed to meaningfully engaging citizens: –Not our competition; and –Very good source of information.  Targeting information –Petitions; –Notices; and –Targeting.  Tips and complaints

Title 5 Certifications/Petitions  Review of Title 5 certifications and petitions;  Where enforcement actions taken for requirement that was not reported in annual certification a Title V claim should also be plead; and  Selective reviews of Title 5 certifications at problematic sources

Cross-Reference of Emission Inventories Information  Otis – –Tracks emissions through integration of TRI data.  Review of Air Quality Monitors  TRI –There are some problems with TRI  Emission Inventories for State Fees –Can also provide additional violations –Emission Factors may under-estimate emissions (Test Orders)