Terriquez, Joe, US EPA, Next Generation Compliance, Missouri Air Compliance Seminar, March 3, 2016

Joe TerriquezAir Compliance & Enforcement Section EPA Region 7

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Rule and Permit Design

Advanced Monitoring

Electronic ReportingTransparency

Compliance Verification

• Improve ability to implement environmental programs with limited resources and ultimately reduce pollution and better protect public health and environment.

• Paper based reporting will become electronic, reducing burden on states and their regulated entities with better data quality.

• Advanced monitoring will give better information on environmental conditions, specific pollution sources, regulated entity performance and government performance

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5 Principles (and 16 tools) Clearer applicability Structural Monitoring: self and third-party E-Reporting and transparency Market forces and incentives

U.S. Environmental Protection Agency 4

Find out about pollution in real time

Facility feedback loops –preventing pollution before it happens

Fence line monitoring

Remote sensing


Data/Information Public Environmental/Community impacts Compliance (Inspection authority) Enforcement Process Rulemaking Citizen Science Environmental Clean Up

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Target inspections (screening tool) Improved inspection compliance results Support information requests Enhance effectiveness of settlements Mitigation Projects Beneficial Environmental Projects

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Objective 1: Identify and track universe of advanced monitoring technologies (Existing and Emerging) Track current EPA inventory and output/outcomes Summary will be shared with states

Inventory of currently used technologies and best practices Outreach to external organizations Gained knowledge can be shared with states

Establish target audiences Who benefits from knowledge Share on an on-going basis

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Objective 2: Collaboration Across EPA offices (e.g. Office of Research and

Development) Identify states’ advanced technology needs and develop

R&D opportunities Partnerships with external organizations Universities would create additional resources for R&D Trade Associations to help establish awareness,

agreements, and joint projects (e.g. best management practices)

Domestically and Internationally Outreach to community/EJ groups Support state efforts in addressing community concerns and

minimizing environmental impacts in EJ areas through implementation of advanced monitoring

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Objective 3: Equipping Establish joint state-federal projects to support E-enterprise Help address resource constraints Help minimize environmental impacts Help address community/EJ concerns

Develop proposal to prioritize purchasing Share data on cost, O&M, results

Identify need for methods/policy/standards Facilitate state compliance and enforcement efforts in use of advanced

technologies Establish Communities of Practice Include federal and state representatives to exchange

knowledge/expertise

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Identify pollution in real time Fence line monitoring Remote sensing Facility feedback – Fix emission

problems near real time O&G, Refineries, Chemical

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Property’s boundary Long-term (48 hrs – 2 wks) Low Cost – Reusable Air Toxics (e.g. benzene) Used at O&G, refineries

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LIDAR for Opacity Addresses Method 9 (limitations) Higher sources (elevated angle) Sun positioning (horizontal or

vertical) Readings day or night Next Step: EPA field testing and

rule-making

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Prototype – ORD Solar Powered Battery Powered Data Logger

Address community concerns

Next step: EPA to begin field testing 15

Portable Sensor VOCs Temperature Relative

humidity

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Testing of flares to determine combustion efficiency

PFTIR works by measuring flare plume gases

We found many flares with poor combustion efficiency that emitted substantial amounts of VOCs

18U.S. Environmental Protection Agency

Citizen hand held sensors GPS Sensors – CO, NO2, O3 Smartphone – App Data uploaded – help provide

air quality info

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http://www.airnow.gov/index.cfm?action=airnow.villagegreen

http://www.airnow.gov/index.cfm?action=airnow.villagegreen

System with smart tools to guide user

Improves quality, reduces error correction costs

Supports transparency tools

EPA NPDES e-reporting rule proposed July 2013

EPA CROMERR CEDRI, CDX,


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• EPA Published in 2005• Legal Framework for E-Reporting• Standards Apply to States, Tribal & Local Agencies• All EPA Systems for Electronic Data Collection• Central Data Exchange (CDX)• Office of Environmental Information (OEI)

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• Meets Agency Standards for:• Maintain Integrity of Electronic Document• Validity of Electronic Signature (Responsible Official)• Opportunity to Review/Repudiate Copy of Record• Agency Reporting Approval Process• EPA Regulations: 40 CFR Parts 60 and 63• Requires CROMERR Certification

Function/Services:• Source/Industry Registration (for CEDRI)• Offers Archives System• Supports Multiple Report Submittals (at one time)• Includes Log of Transaction• Establishes Electronic Audit Trail• Provides Receipts• Supports Digital Signature Requirements• Allows Agency Approval/Disapproval

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Function/Services (cont.)• Some Federal Fee Payment (Pay.gov)• Offers Machine-to-Machine Data Exchange• Allows Data Transformations• Secure Data Exchange System

(PKI/Encryption)• Accepts Variety of File Formats (Webs

Forms, XML, binary)• Allows Public Access (WebFIRE)

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• Operational Since FY 2012• Electronic/Web-Based Tool• Available Only thru CDX• Requires Registration• Allows Submission of Compliance Reports/Emissions

Data• Managed by Office of Air and Radiation (OAR)

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• Reporting Requirements/ 40 CFR Parts 60 and 63• Specific Reporting Format• Allowable Reporting (40 CFR Part 60 and 63):• Performance Test Reports• Relative Accuracy Test Audits (RATAs)• Initial Notification Reports• Notice of Compliance Status Reports (NOCSR)• Air Emission Reports (6 Months/Semi-Annual)• Submittal Packages (Combined Reports)• WebFIRE (Reviewable by Public)

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Allowable Reporting 40 CFR Parts 60 and 63• Performance Test Reports and RATAs• Use Electronic Reporting Tools (ERT)• Build-In Microsoft Access Program (Forms)• Upload Files to CDX using CEDRI• NOCSRs and Initial Notification Reports• PDF Files• Uploaded to CDX using CEDRI• AERs (Semi-Annual/6 months)• Completed Thru Fillable Forms• Launched within CEDRI 31

Public accountability to improve facility and government performance

Well designed transparency can drive change, e.g., Restaurant health inspection

grades


Strategic targeting and data analysis to identify and address most serious violations

Application of new enforcement technology Incorporation of Next Gen tools in enforcement

settlements


Required maintenance plan using infrared cameras to survey tanks for leaks at natural gas compressor stations

34U.S. Environmental Protection Agency

Improve ability to implement programs with limited resources and ultimately reduce pollution and better protect public health and environment.

Electronic reporting will reduce burden on states and their regulated entities and provide better data quality.

Advanced monitoring will give better information on environmental conditions, pollution sources, regulated entity and government performance.


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Make useful information about compliance available and accessible using 21st century technologies

Share data efficiently and securely with regulatory community

Streamline and modernize how EPA collects data and information

Expand transparency to improve performance of government and industry

Improved environmental protection for everyone

Questions?

U.S. Environmental Protection Agency