Air Quality Air Quality

Compliance Management Compliance Management for for

Small & Mid-Size Small & Mid-Size

Rural UtilitiesRural Utilities

Air Quality - Permitting / Compliance / Air Quality - Permitting / Compliance / MonitoringMonitoring

Office Locations inOffice Locations inAnchorage, AKAnchorage, AKJuneau, AKJuneau, AKPortland, ORPortland, ORTucson, AZTucson, AZCedar City, UTCedar City, UT

Experience in Experience in (almost 20 years)(almost 20 years)

UtilitiesUtilitiesMining / ConstructionMining / ConstructionOil & Gas / Refining / PipelinesOil & Gas / Refining / PipelinesSeafood Industry / SPCC PlansSeafood Industry / SPCC Plans

Presenter: Presenter: Erik Haas, PrincipalErik Haas, Principal erik@hmhconsulting.org / www.hmhconsulting.org / www.hmhconsulting.org

• State/Local Air Quality Rules

• 40 CFR 60 (NSPS), Subparts – Dc: small steam generators– K-Kb: Petroleum Storage Tanks– O: Sewage Treatment Plants– GG: Utility Gas Turbines– E, AAAA-FFFF: Mun. Waste Incineration– IIII: Stationary Diesel Engines

• new engines – establish emission limits by model year 2005 and later

• Emission limits certified by manufacturer or Source Testing (Appendix A)

– JJJJ: Stationary Spark-Ignition Engines– KKKK: Stationary Combustion Turbines– OOOO: Crude Oil/Ntl. Gas

Production/Transmission/Distribution

Small Utilities - AQ Rules & Small Utilities - AQ Rules & Regulations Regulations

• 40 CFR 61 (NESHAP), Subparts E (Mercury), M (Asbestos)

• 40 CFR 63 (NESHAP by source categories), Subparts:– ZZZZ: Stat. Recip. Internal Combustion Engines (RICE)

• Retrofit-Control Equipment

• Existing Engines - Prior to 2002/2006

• Install Oxy-Catalysts

• Performance Testing – (hand-held analyzers) vs. Appendix A:Testing Methods

– JJJJJJ: Indust./Comm./Institut. Boiler Area Sources

• 40 CFR 98 – Mandatory Greenhouse Gas Reporting

Small Utilities - AQ Rules & Small Utilities - AQ Rules & Regulations – contRegulations – cont..

Environmental Management Systems Environmental Management Systems (EMS) for Small/Mid-Size Utilities(EMS) for Small/Mid-Size Utilities

PRINCIPLE: Environmental StewardshipEnvironmental Stewardship

•Full ISO 14001 very comprehensive/expensiveFull ISO 14001 very comprehensive/expensive

•Adapted Structure of ISO 14001Adapted Structure of ISO 14001 Planning Planning DOINGDOING CHECKINGCHECKING ACTING ACTING

“Transition from a knowledge-based and orally-directed compliance management system to a more defined structured and documented management system. “

PLANNINGPLANNING

–STRUCTURE STRUCTURE

• Position Responsibilities

• Accountability

–ESTABLISHESTABLISH ASPECTS, OBJECTIVES AND TARGETS ASPECTS, OBJECTIVES AND TARGETS

• Aspects - primary environmental issues

• Objectives - measurable multi-year goals as indicators for progress

• Targets - yearly measuring stick toward the multi-year Objective

–ESTABLISH ESTABLISH

• SOPs, Work Sheets, Forms, Directives, Quarterly Calendars, etc.

Environmental Management Systems (EMS) for Small/Mid-Size Environmental Management Systems (EMS) for Small/Mid-Size Utilities – cont.Utilities – cont.

• DOINGDOING• EVERYBODY HAS A ROLE IN GETTING THE JOB DONE EVERYBODY HAS A ROLE IN GETTING THE JOB DONE

• IMPROVE SKILLS, KNOWLEDGE & TRAININGIMPROVE SKILLS, KNOWLEDGE & TRAINING

• CHECKINGCHECKING• OPERATIONAL OVERSIGHT OPERATIONAL OVERSIGHT (Facility Foreman/Manager)(Facility Foreman/Manager)

• ENVIRONMENTAL COMPLIANCE VERIFICATION ENVIRONMENTAL COMPLIANCE VERIFICATION (Env. Coord.)(Env. Coord.)

• INDEPENDENT AUDITS OF THE EMS - INDEPENDENT AUDITS OF THE EMS - Independent Contract Firm – other Independent Contract Firm – other than EMS Consultantthan EMS Consultant

• ACTINGACTING Continual ImprovementContinual Improvement

• QUARTERLY REVIEW AND OVERSIGHT QUARTERLY REVIEW AND OVERSIGHT

• THE ANNUAL EMS REVIEW THE ANNUAL EMS REVIEW Re- assessment of Aspects/Targets/ObjectivesRe- assessment of Aspects/Targets/Objectives

• APPROVAL & EXECUTION OF APPROVAL & EXECUTION OF any EMS CHANGES any EMS CHANGES Facility Manager w/ approval by Utility BoardFacility Manager w/ approval by Utility Board

Environmental Management Systems (EMS) for Small/Mid-Size Environmental Management Systems (EMS) for Small/Mid-Size Utilities – cont.Utilities – cont.

Environmental Management Systems (EMS) for Small/Mid-Size UtilitiesEnvironmental Management Systems (EMS) for Small/Mid-Size UtilitiesNome, AKNome, AK

Clean-Coal Project ChallengesClean-Coal Project Challenges

• 50 MW Clean-Coal Project in Healy, AK - Adjacent to Coal Mine 50 MW Clean-Coal Project in Healy, AK - Adjacent to Coal Mine

• At border of Denali Ntl. ParkAt border of Denali Ntl. Park

• TRW Clean-Coal Combustion System/B&W Spray Dryer AbsorberTRW Clean-Coal Combustion System/B&W Spray Dryer Absorber

Healy Clean Coal Project – Course of EventsHealy Clean Coal Project – Course of Events

• Construction from 1995-1997 – cost around $300 million• US-DOE: $120MUS-DOE: $120M• AIDA: $140MAIDA: $140M• AK-Legislature: $25MAK-Legislature: $25M• GVEA/Usibelli Coal: $10MGVEA/Usibelli Coal: $10M

• Met emission limits and performance standards

• Too expensive to operate for GVEA – return to AIDA

• Attempt to remove Clean-Coal Technology – Conv. Technology

• ADEC/EPA agreed to re-issue Air Permit

• Sierra Club files Injunction – Impacts on Denali Ntl. Park

• Year 2000 - Shut down/moth-balled

Challenges with Utility MR&R at Rural Challenges with Utility MR&R at Rural UtilitiesUtilities

– Ever increasing regulatory burdenEver increasing regulatory burden– Monitoring/Recordkeeping/ReportingMonitoring/Recordkeeping/Reporting

• fuel gas from producersfuel gas from producers

• fuel oil deliveriesfuel oil deliveries

• KWhr produced / Internal LossesKWhr produced / Internal Losses

• Transmission Line LossesTransmission Line Losses

• Individual household consumptionsIndividual household consumptions

– Power Cost Equalization Reporting IssuesPower Cost Equalization Reporting Issues• Where does Energy go ? Excessive line Where does Energy go ? Excessive line

losses ???losses ???

• ReportedReported power generation efficiencies way power generation efficiencies way highhigh

• Very low household power consumptionsVery low household power consumptions

Challenges with Utility MR&R at Rural Utilities – Challenges with Utility MR&R at Rural Utilities – Barrow, AKBarrow, AK