Workshop T Ohio: Major Air Permitting, Regulatory & Compliance Developments Tuesday, March 21, 2017 3:30 p.m. to 4:45 p.m.
Biographical Information Maxine D. Dewbury, Environmental Regulatory & Regional HSE Manager The Procter & Gamble Company 8256 Union Centre Boulevard, West Chester Ohio, 45069 Phone: 513-634-9557 dewbury.md@pg.com Maxine Dewbury is U.S. Environmental Regulatory and Regional HSE Manager for The Procter & Gamble Company. Maxine has been responsible for U.S. Federal Environmental Regulatory influence, focused on Clean Air Act issues for the past 17 years. In addition to working with trade associations and U.S. EPA on regulations, Maxine is responsible for helping P&G sites and regional resources obtain air permits and meet HSE regulatory requirements. Prior to this assignment, Maxine has held a variety of positions in her 37 year career with P&G. These include Risk Manager at P&G’s Oxnard, California site; Plant Quality Manager at the Flint River, Georgia Pulp Mill; Environmental Manager for the Cellulose & Specialties Division; and several process and project engineering assignments. Maxine graduated in 1979 from Louisiana Tech University with a B.S. in Chemical Engineering. Robert F. Hodanbosi, Chief, Division of Air Pollution Control Ohio EPA, Lazarus Government Center, 50 West Town Street, Columbus, OH 43215 614.644.2270 Fax: 614.644.3681 bob.hodanbosi@epa.state.oh.us Bob Hodanbosi became chief of the Division of Air Pollution Control (DAPC), Ohio Environmental Protection Agency (Ohio EPA) in September 1992. His current duties include being responsible for the air pollution control program for the state of Ohio and development of the programs needed to comply with the Clean Air Act Amendments. In 2004, Bob was selected to represent state permitting authorities on the Title V Permit Performance Task Force that was formed by the U.S. EPA's Clean Air Act Advisory Committee. Bob has also had the opportunity to testify at U.S. House and Senate committees on Clean Air Act implications for facilities in Ohio. From May 1987 to September 1992, his position was assistant chief of DAPC and manager of the Air Quality Modeling and Planning Section, DAPC, Ohio EPA. From April 1978 to May 1987, as manager of the Air Quality Modeling and Planning Section, his main duties included: development of the technical support for air pollution control regulations for criteria air pollutants; atmospheric dispersion modeling; air quality designations under Section 107 of the Clean Air Act and, development of new source review procedures. Since the 1980's, Bob has represented Ohio EPA on the Ohio Coal Development Office, Technical Advisory Committee. From January 1977 to April 1978, his position was supervisor of the Environmental Assessment Unit, DAPC, Ohio EPA. The main responsibilities of this position involved the supervising of all air quality evaluation and atmospheric dispersion modeling activities for DAPC. From June 1973 to December 1976, he held a position in the Northeast District Office/Engineering Services Section, DAPC, Ohio EPA. The main function of this position involved the engineering review of air pollution permit applications. Bob is a member of the American Institute of Chemical Engineers and Air & Waste Management Association, and is registered as a Professional Engineer in the state of Ohio. Bob has lectured extensively on topics relating to the requirements under the Clean Air Act and the controls needed to meet air quality standards. Bob received his Master's of Science degree in Chemical Engineering at the Cleveland State University in 1977, and a Bachelor in Chemical Engineering at the Cleveland State University in 1973. In addition, he completed post-graduate courses in fluid mechanics and turbulence at the Ohio State University.
Biographical Information William H. Haak, Haak Law, LLC 216.772.3532 Cleveland, Ohio 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.
26 nd Annual Sustainability and Environmental, Health & Safety Symposium Session T: Ohio – Major Air Permitting, Regulatory and Compliance Developments March 21, 2017 Bob Hodanbosi, Chief, OEPA Dept of Air Pollution Control William H. Haak, Haak Law, LLC Maxine Dewbury, Regulatory Manager, Procter & Gamble
Major Air Permitting, Regulatory and Compliance Developments Topics: • Startup/Shutdown/Malfunction Developments • Ozone NAAQS Updated • Interstate Transport • EPA’s New Refrigerant Rule • Regulatory Reform • Legal & Regulatory Developments • Operating in an Uncertain Regulatory Climate
Sustainability and Environmental Health & Safety Ohio EPA, Division of Air Pollution Control March 21, 2017 Robert Hodanbosi
Topics • Startup, Shutdown & Malfunction SIP Call • Ozone Update • Interstate Transport
Startup, Shutdown & Malfunction SIP Call
Startup, Shutdown & Malfunction SIP Call • U. S. EPA settled a lawsuit with the Sierra Club that addresses rules associated with startup, shutdown and malfunctions in 36 states • U.S. EPA proposed a “SIP Call” in 36 states (including Ohio) that require that states modify their rules because these rules contain language “inconsistent with the Clean Air Act” • These states rules were previously approved by U.S. EPA – but are now objectionable • State rule allow “Director’s discretion” • U.S. EPA claims citizens suits are prevented
Startup, Shutdown & Malfunction SIP Call • U. S. EPA went further in Ohio….. • Even though not part of the lawsuit, U.S. EPA identified the Scheduled Maintenance Rule as also one of the objectionable rules • U.S. EPA did not ask questions on how Ohio rules operate • U.S. EPA did not consult with Ohio EPA prior to lawsuit settlement • U.S. EPA made incorrect errors and assumptions
Startup, Shutdown and Malfunction SIP Call – State Rule Revision Process • Several draft of rules sent to stakeholders • Wide range of comments • Received comments on “Early Stakeholder Outreach” solicitation. • Issued “Interested Party” packages • Received detailed comments
Startup, Shutdown & Malfunction SIP Call • Objectionable Rule 1: OAC 3745‐15‐06(C) – Malfunction of equipment – The Director retains the responsibility to evaluate any report submitted pursuant to this rule. The Director shall take appropriate action upon a determination that the reporting requirements of this rule have not been satisfied, that the equipment was not properly operated and maintained prior to breakdown, that shutdown of the source or operation during the period of maintenance or breakdown was or has become practicable, that the shutdown or breakdown was or has become avoidable, or was induced or prolonged in bad faith, or that the emissions endanger or tend to endanger the health or safety of the public.
Startup, Shutdown & Malfunction SIP Call • Objectionable Rule 1: OAC 3745‐15‐06(C) – Malfunction of equipment • Ohio EPA Response: • Adding definition of “malfunction” • Adding “work practice” standards • Director still can review submittal/malfunction report
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