Workshop N Operationalizing Air Permit Compliance: Engaging Operations Personnel to Make Your EHS Job Easier Tuesday, March 21, 2017 2 p.m. to 3:15 p.m.
Biographical Information William H. Haak, Founder, Haak Law LLC Cleveland, Ohio 216.772.3532 whh@haaklawllc.com William H. Haak is the Founder of Haak Law LLC (www.haaklawllc.com) – an environmental, health & safety legal and consulting firm based in Cleveland, Ohio. He has more than 15 years of experience in occupational safety law and worker safety, and over 20 years of experience in environmental law (including extensive experience in air pollution control law and multi-media environmental compliance). Mr. Haak practices nationally in the United States and consults globally on all matters related to the EHS field (plus security and crisis management). Mr. Haak graduated from The University of Akron (Business Finance) and Case Western Reserve University School of Law (J.D. with an emphasis on litigation and trial practice). Following law school, he worked as an Assistant Attorney General in the State of Ohio Attorney General’s Environmental Enforcement Section. As counsel to Ohio EPA, Mr. Haak’s practice was focused primarily on civil and administrative air pollution control cases. During his time with the Attorney General’s Office, Mr. Haak resolved civil environmental enforcement actions resulting in civil penalties totaling approximately $4 million. Prior to forming Haak Law LLC, Mr. Haak was Senior EH&S Counsel for General Electric. He supported GE’s Appliances and Lighting Businesses, and was engaged in complex air permitting issues for other GE businesses nationwide. Mr. Haak has also been Associate General Counsel – EH&S for Hexion Specialty Chemicals in Columbus, Ohio, and Senior Regulatory Law Counsel for Owens Corning in Toledo, Ohio. He served overseas in the former Soviet Union (Ukraine) as an Environmental Enforcement Specialist with the American Bar Association’s Central & East European Law Initiative ("ABA/CEELI"). Haak is a frequent lecturer to attorneys, engineers, and environmental professionals on topics concerning federal and state air pollution law. In addition, he has taught as an adjunct faculty member at the University of Central Florida in Orlando and Columbus State in Columbus, Ohio. Since 2005, Haak has taught classes focusing on Air Pollution Law and Occupational Safety and Health Law at The University of Toledo College of Law as an Adjunct Professor. Sheri L. Bussard Environmental Engineer, University of Cincinnati Utilities Central Utility Plant, 3000 Glendora Avenue, Cincinnati, OH 45221 Phone: 513-556-2542 Fax: 513-558-1739 E-mail: sheri.bussard@uc.edu Ms. Bussard is the environmental engineer for the University of Cincinnati Utilities department. She is responsible for the utility’s continuous emission monitoring programs as well as compliance with the site’s Title V permit and other applicable regulations. She coordinates emission testing for the site and manages the completion and submittal of environmental reports. Prior to joining the University of Cincinnati, Ms. Bussard worked as an environmental consultant. She became a senior project manager with a breadth of multimedia compliance knowledge, focused primarily in air and EPCRA. Her experience includes air emission inventories, air permitting, air permit/regulatory compliance, EPCRA compliance, visible emission project management, and multimedia compliance audits. Ms. Bussard received a B.S in Civil Engineering and an M.S. in Environmental Engineering from the University of Cincinnati.
Biographical Information Mike Zimmer, P.E., Principal Consultant Trinity Consultants, 1717 Dixie Highway, Ste 900, Covington, KY 41011 859.341.8100 ext. 103 mzimmer@trinityconsultants.com Mike Zimmer serves as the manager of Trinity Consultants' operations in Northern Kentucky and Greater Cincinnati. Mike has more than 24 years of technical experience in the air quality field assisting clients with air quality management (auditing, regulatory strategy assessments, compliance management tools, emission inventories), dispersion modeling (increment, NAAQS, Class I Area, AQRVs, odor, litigation support, BART), and permitting (Kentucky, Ohio, and Indiana installation/construction permits, Title V operating permits, PSD, BACT, SOCMI, NSPS, NESHAP, MACT, etc.). In his 12-year tenure with Trinity, he has worked with a number of industries, including organic & inorganic chemicals, steel industry, primary and secondary aluminum, ferroalloy industry, gray/ductile iron foundry, metal fabrication, nitric acid manufacturing, printing, surface coating, power generation, automobile manufacturing, rubber products, roofing products, mineral products industry, reinforced plastic composites, gypsum manufacturing, mining, cosmetics, Portland cement, computer manufacturing, fiberglass pool manufacturing, drum reconditioning, coal-to-gas, oil & gas, brick manufacturing, and others. As registered Professional Engineer, Mike has an extensive background in various aspects of environmental engineering, from preliminary stack design to ventilation system modifications to choosing the suitable air pollution control devices. Mike has authored and co-authored various papers and presented to industry at national and regional AWMA conferences, Environmental, Health & Safety Symposiums sponsored by the Manufacturer’s Educational Council (MEC), and the Energy Utility Environmental Conference. Additionally, Mr. Zimmer is an instructor for Trinity’s Air Regulations and Permitting in Kentucky . Mike earned a B.S. in Civil/Environmental Engineering from the University of Cincinnati.
Beyond EHS Staff: ”Operationalization” of Compliance Session N March 21, 2017 William H. Haak Haak Law LLC HAAK LAW LLC William H. Haak Tel: 216.772.3532 Environmental, Health & Safety whh@haaklawllc.com Legal and Consulting Services
At the Outset… • Your job (EHS) is the hardest job at any facility • Whether you’re surrounded by “friends” or “enemies” is largely up to you - “ Risk multipliers ”, or - “ Force multipliers ”? • How can you create true partners out of non- EHS leadership and operations personnel? HAAK LAW LLC William H. Haak Tel: 216.772.3532 Environmental, Health & Safety whh@haaklawllc.com Legal and Consulting Services
We All Know the Stories… • “I didn’t know that had an environmental impact!” • Bypassed control equipment • Unpermitted “modifications” • A PTI that “ we need, like, yesterday ” • Unreported deviations, malfunctions, exceedances • Dude! Where’s my dust collector? HAAK LAW LLC William H. Haak Tel: 216.772.3532 Environmental, Health & Safety whh@haaklawllc.com Legal and Consulting Services
What’s the Root Cause? • “ What we have here is a failure to communicate… ” • Is lack of communication a disease, or a symptom? HAAK LAW LLC William H. Haak Tel: 216.772.3532 Environmental, Health & Safety whh@haaklawllc.com Legal and Consulting Services
Elements of Poor Communication • Lack of understanding (or just not caring) • “That’s not my job…” • Intentional under-communication • Spiteful over-communication • Functions operating “in silos” • A blame and shame atmosphere HAAK LAW LLC William H. Haak Tel: 216.772.3532 Environmental, Health & Safety whh@haaklawllc.com Legal and Consulting Services
3 Steps to Better Communication • Educate… - Yourselves about the business and processes - Your “allies” about what compliance means • Integrate… - Yourselves into non-EHS discussions and rhythms - Your “allies” into how you “make the sausage” • Motivate… - Establish metrics and accountability outside of EHS - “Operationalizing” EHS means moving ownership HAAK LAW LLC William H. Haak Tel: 216.772.3532 Environmental, Health & Safety whh@haaklawllc.com Legal and Consulting Services
Best Practices for Ensuring Air Permit Compliance Presented by: Sheri Bussard Environmental Engineer - Utilities University of Cincinnati
University of Cincinnati Utilities • Provide electricity, steam for heat, and chilled water for cooling to 100+ UC buildings and several hospitals • 2 separate utility plants • Title V air permit
Title V Permitting Program • WHO - sites with large potential emissions (major sources) • WHY - standardize air permit and permitting process • HOW - consolidate all permits into one document • BENEFIT – Title V Permit includes all applicable air pollution control requirements for entire site • CHALLENGE – Title V Permit includes all applicable air pollution control requirements for entire site
Know Your Permit! • Read and understand your permit • Highlight action items • Renewal – compare to previous permit for changes
Recommend
More recommend
