1. Bureau of Air Quality Control1 Compliance Monitoring Strategy in Houston Arturo J. Blanco City of Houston Lee P. Brown, Mayor Department of Health and Human Services Dr. M. des Vignes-Kendrick, MD, MPH Director

2. Bureau of Air Quality Control2 CMS Goals More effective use of city resources netting greatest impact in reducing unauthorized air emissions Complete and adequate coverage of sources of interest to EPA, State, and COH Increased focus in problem areas

3. Bureau of Air Quality Control3 Staff resources vs compliance assurance… ~32 technical staffs/~70 majors & >3,000 minors ~800 air complaints/year ~2,400 emission points in sources of interest (including 2800/2911 SIC) extensive regulatory spectrum (state/federal) – exacerbated by severe O3 non-attainment status

4. Bureau of Air Quality Control4 …Staff resources vs compliance assurance 21 cooling towers & 301,000 LDAR components ~100 emission events (upsets)/year

5. Bureau of Air Quality Control5 Sources of interest… 1 full CCI & 1 additional (but limited) on-site review per 5-year period, per major source Annual review/major source thru Title V – tests RE accountability & reliability 100% review of reportable/reported emissions events (upsets)

6. Bureau of Air Quality Control6 …Sources of interest Hands-on monitoring of targeted air emission areas Widely expanded attention to sources within 20% of major source threshold

7. Bureau of Air Quality Control7 Increased focus in problem areas Highly reactive volatile organic compounds (HRVOCs) Excessive emissions from unauthorized emission events (upsets) Hands-on air sampling Gaps in emissions inventory Inconsistencies in deviation reporting

8. Bureau of Air Quality Control8 HRVOCs Butadiene, Ethylene, Propylene and other alkenes Discovered significant leak emission rate from two cooling towers EPA Method 21 followed incorrectly, raising emissions issues on a wide range of LDAR components Incorrect inventory of number of valves reported thru NSPS and NESHAP Increased number of HPV cited

9. Bureau of Air Quality Control9 Unauthorized EE (upsets) Scrutinizing each and every notified event as well as reviewing all of their corresponding final reports – yielding a thorough process/equipment problem understanding Excessive emissions recommendations to TCEQ – affecting compliance history of source

10. Bureau of Air Quality Control10 Gaps in emissions inventory Developing a project proposal to examine and trace air emission plumes to better understand sources of emissions Developing a work plan strategy, correlating available emissions data with GIS techniques – hopefully resulting in improved investigative leads

11. Bureau of Air Quality Control11 Title V vs deviation reporting Improved scrutiny of reported annual certifications Closer scrutiny of reported and unreported EE with respect to deviation reporting Closer scrutiny of emissions information reported under NESHAP, NSPS and HON

12. Bureau of Air Quality Control12 SUMMARY Working harder but smarter in terms of wide source coverage while emphasizing air emissions focus (not just a paper exercise) Meeting national and state program priorities while better tending to region specific needs More practical field investigations leading to problem solving dialog with RE

13. Bureau of Air Quality Control13 Compliance Monitoring Strategy in Houston And the work continues…affording flexibility…adjusting to varying needs…hopefully leading to problem solving alternatives to our air pollution challenges…