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Air Quality Compliance Management for Small & Mid-Size Rural Utilities

Air Quality Compliance Management for Small & Mid-Size Rural Utilities. Air Quality - Permitting / Compliance / Monitoring Office Locations in Anchorage, AK Juneau, AK Portland, OR Tucson, AZ Cedar City, UT Experience in (almost 20 years) Utilities

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Air Quality Compliance Management for Small & Mid-Size Rural Utilities

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  1. Air Quality Compliance Management for Small & Mid-Size Rural Utilities

  2. Air Quality - Permitting / Compliance / Monitoring Office Locations in Anchorage, AK Juneau, AK Portland, OR Tucson, AZ Cedar City, UT Experience in (almost 20 years) Utilities Mining / Construction Oil & Gas / Refining / Pipelines Seafood Industry / SPCC Plans Presenter: Erik Haas, Principal erik@hmhconsulting.org / www.hmhconsulting.org

  3. Small Utilities - AQ Rules & Regulations • 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

  4. Small Utilities - AQ Rules & Regulations – cont. • 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

  5. Environmental Management Systems (EMS) for Small/Mid-Size Utilities PRINCIPLE: Environmental Stewardship • Full ISO 14001 very comprehensive/expensive • Adapted Structure of ISO 14001 • Planning • DOING • CHECKING • ACTING “Transition from a knowledge-based and orally-directed compliance management system to a more defined structured and documented management system. “

  6. Environmental Management Systems (EMS) for Small/Mid-Size Utilities – cont. PLANNING • STRUCTURE • Position Responsibilities • Accountability • ESTABLISHASPECTS, 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 • SOPs, Work Sheets, Forms, Directives, Quarterly Calendars, etc.

  7. Environmental Management Systems (EMS) for Small/Mid-Size Utilities – cont. • DOING • EVERYBODY HAS A ROLE IN GETTING THE JOB DONE • IMPROVE SKILLS, KNOWLEDGE & TRAINING • CHECKING • OPERATIONAL OVERSIGHT (Facility Foreman/Manager) • ENVIRONMENTAL COMPLIANCE VERIFICATION (Env. Coord.) • INDEPENDENT AUDITS OF THE EMS - Independent Contract Firm – other than EMS Consultant • ACTINGContinual Improvement • QUARTERLY REVIEW AND OVERSIGHT • THE ANNUAL EMS REVIEW Re- assessment of Aspects/Targets/Objectives • APPROVAL & EXECUTION OF any EMS CHANGES Facility Manager w/ approval by Utility Board

  8. Environmental Management Systems (EMS) for Small/Mid-Size Utilities Nome, AK

  9. Clean-Coal Project Challenges • 50 MW Clean-Coal Project in Healy, AK - Adjacent to Coal Mine • At border of Denali Ntl. Park • TRW Clean-Coal Combustion System/B&W Spray Dryer Absorber

  10. Healy Clean Coal Project – Course of Events • Construction from 1995-1997 – cost around $300 million • US-DOE: $120M • AIDA: $140M • AK-Legislature: $25M • GVEA/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

  11. Challenges with Utility MR&R at Rural Utilities • Ever increasing regulatory burden • Monitoring/Recordkeeping/Reporting • fuel gas from producers • fuel oil deliveries • KWhr produced / Internal Losses • Transmission Line Losses • Individual household consumptions • Power Cost Equalization Reporting Issues • Where does Energy go ? Excessive line losses ??? • Reportedpower generation efficiencies way high • Very low household power consumptions

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

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