 |
Facility operators should keep in mind that states must comply with their SIPs and that that can trigger enforcement actions against firms that fail to obtain proper air permits and otherwise have emissions that exceed limits incorporated into the SIP. This is especially true in urban coastal areas where air quality is subject to both on- and off-shore emissions sources and maintaining air quality requires constant vigilance.
In the state of Rhode Island where ozone has long been a problem, both the EPA and the state are working hard to enforce air emissions regulations. In 2013, three boatyards in Rhode Island were cited by the EPA for numerous CAA violations related to their painting and repair operations and subsequent emissions of volatile organic compounds (VOCs). In boatyards and other operations that use paints, coatings, and associated substances such as thinners, VOC emissions can exceed permit limits and caps depending on the types of products used, how they are applied, and what, if any, mitigation practices are employed to minimize emissions.
Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it out today and get an the 2013 EHS Salary Guide, absolutely free. Download Now.
Achieving compliance with ozone limits is important because ground-level ozone (a major component of smog) is created when VOCs, oxides of nitrogen (NOx), and sunlight come together. The resulting pollution causes a broad range of health issues for people with respiratory or heart problems and can reduce lung function and inflame the lining of the lungs, as well. Eliminating ozone and smog is essential to ensuring clean, healthy air, and enforcement is essential to fulfilling that objective.
For example, the first two enforcement actions occurred at yacht repair facilities in Newport and Portsmouth, R.I., that were cited for failing to use paints and other coatings that meet low-VOC standards. As a result, both facilities were required to obtain CAA permits from the state with caps on VOC emissions, use low-VOC paints and coatings, and comply with applicable recordkeeping and certification requirements. In addition, the companies were also required to use paint guns with high transfer efficiencies, use best practices for minimizing VOC emissions during painting and cleanup activities, and again comply with applicable recordkeeping and reporting requirements. The companies were also penalized $31,000 and $31,500, respectively.
While these two enforcement actions were almost identical in allegations, compliance requirements, and monetary penalties assessed, a third such action resulted in a much more costly scenario, but one that will likely ensure much lower emissions.
Everything You Need for Environmental Compliance
Enviro.BLR.com puts everything you need at your fingertips, including practical RCRA, CAA, CWA, hazardous waste regulatory analysis and activity, news, and compliance tools. Try it at no cost or risk and get a FREE report.
This shipbuilding and ship repair facility, located in Warren, R.I., was cited by the EPA for violating state and federal clean air regulations when it used paints and other coatings that exceeded allowable emission limits, did not keep records of its paint usage, and also did not submit required notifications and reports to both state and federal agencies. In addition, the facility was also cited for failing to obtain New Source Review permits in 2009, when it acquired new paint spray guns, failing to apply for or obtain a CAA Title V operating permit or emission cap permit, and failing to comply with applicable certification and recordkeeping requirements for surface coating metal parts and products.
In addition to obtaining all necessary permits and submitting a plan for compliance with the NESHAP for Shipbuilding and Ship Repair Facilities to the EPA and the state, the company will perform a Supplemental Environmental Project (SEP) with a minimum cost of $230,000 to include construction and use of a forced-ventilation, modular vinyl structure covering the facility’s construction ways. The new structure must have and employ an exhaust filtration system during sandblasting and painting operations to reduce harmful VOC and particulate emissions. The company also received a $24,000 penalty.