New This Month Student Corner: How Should …pubs.awma.org/gsearch/em/2012/4/01-6307 April EM...

Also in this issue:

The Complete Streets Concept: Promoting Safe, Efficient, and Sustainable Transportation

IT Insight: Change Happens… Embrace It!

New This MonthStudent Corner: How Should Students

Prepare for the Job Market?

APRIL 2012

Utility and Boiler MACTStakeholder perspectives on the final electric utility Maximum Achievable Control Technology (MACT) standardsand proposed industrial boiler MACT rule

KING WILLIAM HISTORIC DISTRICT TOURTuesday, June 19 8:30 am - 12:30 pm

Learn about San Antonio’s German heritage in this beautiful historic district that made up the most elegant part of San Antonio in the late1800’s. Guests will enjoy a 45-minute walking tour of the area, culminating in a visit to either the Steve’s Homestead or the Villa Finale House. Guests will then visit a glass blowing factory. After a morning of learning, we will stop for lunch at the restaurant voted San Antonio’s best Mexican Restaurant (lunch is not included with the ticket).

NATURAL BRIDGE CAVERNS - DISCOVERY TOURTuesday, June 19 9:00 am - 12:00 pm

The Discovery Tour introduces you to an underground world of natural beauty and amazement. Travel through a half-mile of the largest and most spectacular show cavern in Texas. You’ll walk 180 feet below the ground. See awe-inspiring, ancient formations centuries in the making and still growing today, such as stalagmites, stalactites, flowstones, and soda straws.

BELLA OAKS COOKING SCHOOLTuesday, June 19 10:00 am - 1:00 pm

Impress your family and friends with your culinary skills as you learn to make a delicious and authentic Tex-Mex or BBQ meal. This is not just a demonstration, but a totally hands-on cooking experience on a working farm set in the peaceful countryside, only 30 minutes from San Antonio. Our classes are simple enough for the beginners, yet structured to give you enough skills to try out to be the next Food Network Star!

FREDERICKSBURG/HILL COUNTRY TOUR Wednesday, June 20 9:00 am - 5:30 pm

Join us for a day while we experience the beauty and historic charm of Fredericksburg, in the heart of the Texas Hill Country. Beautiful historic buildings line the streets of this unique, quaint town. The “Magic Mile” along Main Street offers exceptional shopping for jewelry, home décor, art, or gifts.Your tour will include stops at two Texas wineries (tasting fees are included) and a delicious sample at Chocolat, a local chocolate factory. An alternative to shopping is the Admiral Nimitz Museum. This outstanding National Museum of the Pacific Theater of WWII showcases the Japanese Garden of Peace.

SAN ANTONIO CITY TOURThursday, June 21 8:30 am - 2:30 pm

You will led by a professional tour guide on in-depth tours of beautiful Mission Concepcion and Mission San Jose. This tour will highlight the amazing and original frescos that have been restored at Mission Concepcion, and guide you through the exquisite church and Indian dwellings at Mission San Jose. Next stop on our morning tour will be the Steves Homestead. This elegant three-story mansion was built in 1876 for Edward Steves, founder of the Steves Lumber Company. Last stop on our San Antonio tour will be at El Mercado, the largest Mexican market outside of Mexico. Lunch will be here (on your own tab) at La Tierra, a restaurant famous for its great Mexican food and bakery items. You will be back at your hotel for a little siesta by 2:30 pm.

www.awma.orgVisit the conference Web site to download the Social Registration Form

http://ace2012.awma.org/ 800-270-3444

Social Program registration includes a guest bag, a ticket to the Rio Grande Reception, daily exhibition, and a continental breakfast Tuesday through Thursday. Explore the heritage of San Antonio by participating in the tours. The tours listed below are priced separately.

SOCIAL PROGRAM & TOURS

REGISTRATION NOW OPEN

CONFERENCE

105TH ANNUAL

2 em april 2012 awma.orgCopyright 2012 Air & Waste Management Association

The Complete Streets Concept: Promoting Safe, Efficient, and Sustainable Transportationby Dean L. Groves and Douglas C. Prentiss, Fay, Spofford & Thorndike Inc.

Across the United States, towns and cities are embracing a movement, known as Complete Streets, that promotes the design and construction of safe and efficient transportation networks. A fully realized Complete Streets plan can improve the local outdoor

environment, including air quality through the reduction of traffic congestion. It also serves to promote nonmotorized transport, enhancedstormwater runoff management, and adds to a community’s green spaces. This article offers an introduction to this new concept that issweeping the nation.Page 26

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awma.org april 2012 em 3Copyright 2012 Air & Waste Management Association

COLUMNSYP Perspective: Untangling the Web:Understanding the Implications of the Boiler Regulations. . . . . . . . . . . . . 30by Leiran Biton

IT Insight: Change Happens… Embrace It! . . . . . . . . . . . . . . . . . . . . . . 32by Jill Barson Gilbert

New This MonthStudent Corner: How Should StudentsPrepare for the Job Market? . . . . . . . 36by Ashok KumarStudent Corner is a new quarterly columnwritten for (and by) student members spon-sored by A&WMA’s Publication Committee.

ASSOCIATION NEWSMessage from the President. . . . . . . . . 4A Big Dealby Merlyn Hough

2012 Annual Conference Preview: . . 40Young Professional and Student Programs

2012 Annual Conference Course and Workshop Offerings. . . . . . . . . . . 42

DEPARTMENTSWashington Report. . . . . . . . . . . . . . . . . . . 13

Canadian Report. . . . . . . . . . . . . . . . . . . . . 23

News Focus. . . . . . . . . . . . . . . . . . . . . . . . . 44

Professional Development Programs . . . . . 47

Calendar of Events . . . . . . . . . . . . . . . . . . . 48

JA&WMA Table of Contents . . . . . . . . . . . 48

EM, a publication of the Air & Waste Management Association (ISSN 1088-9981), is published monthly with editorial and executive offices at One Gateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435. ©2012 Air & Waste Management Association. All rights reserved. Materials may not be reproduced, redistributed, or translated in any form without prior written permission of the Editor. Periodicals postage paid at Pittsburgh and at an additional mailing office. Postmaster: Send address changes to EM, Air & Waste Management Association, OneGateway Center, 3rd Floor, 420 Fort Duquesne Blvd., Pittsburgh, PA 15222-1435. GST registration number: 135238921. Subscription rates are $280/year for nonprofit libraries and nonprofit institutions and $425/year for all other institutions. Additional postage charges may apply. Pleasecontact A&WMA Member Services for current rates (1-800-270-3444). Send change of address with recent address label (6 weeks advance notice) and claims for missing issues to the Membership Department. Claims for missing issues can be honored only up to three months for domes-tic addresses, six months for foreign addresses. Duplicate copies will not be sent to replace ones undelivered through failure of the member/subscriber to notify A&WMA of change of address. A&WMA assumes no responsibility for statements and opinions advanced by contributors to thispublication. Views expressed in editorials are those of the author and do not necessarily represent an official position of the Association.

NEXT MONTH:

Air Quality Measurements for Science and Policy

Utility and Boiler MACTby John D. Kinsman

This month, EM focuses on the final electric utility Maximum AchievableControl Technology (MACT) standards and proposed industrial boiler MACTrule to address hazardous air pollutants, with six articles and perspectives. Gina McCarthy, Assistant Administrator for Air and Radiation at the U.S. Environmental Protection Agency, kicks it off with anoverview of both rules. Bob Bessette of the Council of Industrial Boiler Owners—a trade association ofboiler owners, architect-engineers, universities, and related equipment manufacturers representing 20major industrial sectors—provides an industry reaction to the proposed boiler MACT. The other four invited authors react to the final utility MACT: Ann Weeks of the Clean Air Task Force—a nonprofit environmental organization; Eric Svenson, of the electric power corporation Public Service EnterpriseGroup; John McManus and colleagues of the electric power company American Electric Power; and Eugene Trisko, representing the United Mine Workers of America.Page 6

MATS and Boiler Rules: Practical, Data-Driven Standards That Protect Public Healthby Gina McCarthy, U.S. Environmental Protection Agency

Page 8

Reconsidered Boiler MACT Rule Needs Some Re-Considerationby Robert D. Bessette, Council of Industrial Boiler Owners

Page 14

First Impressions: Administration Directs Flexible Implementation of MATS Ruleby Ann Weeks, Clean Air Task Force

Page 16

Mercury and Air Toxics Standards: The Right Step for Our Nation and Industryby Eric B. Svenson, Jr., Public Service Enterprise Group

Page 18

A Utility Perspective on the Final Mercury and Air Toxics Standardsby John M. McManus, Frank E. Blake, and Paul M. Jackson, American Electric Power

Page 20

MATS + CSAPR: The Case for Policy Coordinationby Eugene M. Trisko, United Mine Workers of America

Page 24

FEATURES

Advertisers’ IndexEM Advertiser (www) Page

EMSL Analytical Inc.

(emsl.com)...............................Inside Front Cover

Lakes Environmental Software Inc.

(weblakes.com)....................................Back Cover

To advertise in EM, call Alison Lizziat 1-412-904-6003.

awma.org

The theme of this month’s EM is Utility and BoilerMACT. Both of these late-2011 air toxics rulemak-ings involve billions of dollars per year in imple-mentation costs and public health benefits over thenext 3–4 years. The feature articles that follow (frommultiple perspectives, with an introductory overviewby John Kinsman of the Edison Electric Institute)are an illustration of the neutral forum that is oneof the core purposes and strengths of A&WMA.

The Boiler MACT webinar held on January 12,2012, was the first joint webinar partnered by theAmerican Institute of Chemical Engineers (AIChE)and A&WMA. Participation in the webinar exceededexpectations, augmented by local panel discussionssponsored by chapters and sections of both AIChEand A&WMA. Look for more of these joint effortsin the future. A&WMA is also hosting several Utilityand Boiler MACT workshops in 2012. Check theevents calendar on www.awma.org for dates andlocations near you.

Lifelong LearningThe Utility and Boiler MACT workshops and webinars are just a few of the many continuouslearning opportunities provided by A&WMA. TheAssociation’s four Councils—Education, Sections &Chapters, Technical, and Young Professional Advisory—are diligently working on relevant and timely programming for 2012 and 2013, including webinars, workshops, specialty confer-ences, professional development courses, and theAnnual Conferences & Exhibitions in San Antonio(June 2012) and Chicago (June 2013).

The importance of lifelong learning was reinforcedto me recently while reading Leaders Who Last byDave Kraft (Crossway, 2010). He reviewed fivecharacteristics that enabled leaders to finish well,and the second of the five included: “Being an effective leader is a matter of being a lifelong learner,

A&WMA HEADQUARTERS

Robert E. Hall, QEPInterim Executive Director

Air & Waste Management AssociationOne Gateway Center, 3rd Floor420 Fort Duquesne Blvd.Pittsburgh, PA 15222-14351-412-232-3444; 412-232-3450 (fax)[email protected]

ADVERTISINGAlison [email protected]

EDITORIAL Lisa BucherManaging [email protected]

EDITORIAL ADVISORY COMMITTEEDan L. Mueller, P.E., ChairZephyr Environmental CorporationTerm Ends: 2013

Mingming Lu, Vice ChairUniversity of CincinnatiTerm Ends: 2013

John D. BachmannVision Air ConsultingTerm Ends: 2012

Jane C. BartonPatterson ConsultantsTerm Ends: 2012

Gary Bramble, P.E.Dayton Power and LightTerm Ends: 2014

Prakash Doraiswamy, Ph.D.RTI InternationalTerm Ends: 2014

Steven P. Frysinger, Ph.D.James Madison UniversityTerm Ends: 2012

Christian HogrefeU.S. Environmental Protection AgencyTerm Ends: 2013

John D. KinsmanEdison Electric InstituteTerm Ends: 2014

Miriam Lev-On, Ph.D.The LEVON GroupTerm Ends: 2012

Julian A Levy, Jr.Independent ConsultantTerm Ends: 2012

Charles E. McDadeUniversity of California at DavisTerm Ends: 2012

Ann McIver, QEPCitizens Energy GroupTerm Ends: 2014

Mark R. Manninen3MTerm Ends: 2014

Teresa RaineERMTerm Ends: 2014

S.T. RaoU.S. Environmental Protection AgencyTerm Ends: 2012

Jacqueline SibbliesIndependent ConsultantTerm Ends: 2014

Abhilash Vijayan, Ph.D., P.E., QEPCalifornia Air Resources BoardTerm Ends: 2014

Susan S.G. WiermanMid-Atlantic Regional AirManagement AssociationTerm Ends: 2012

James J. Winebrake, Ph.D.Rochester Institute of TechnologyTerm Ends: 2012

PUBLICATIONS COMMITTEEMichael T. KleinmanUniversity of California, IrvineTerm Ends: 2014

A BIG Dealby Merlyn [email protected]

learning at all times, under all circumstances, fromall sorts of people—even your kids!”

My vision for the Association is a growing numberof both young and seasoned professionals activelyinvolved in all programming and learning areas ofthe Association. I see the combined benefits of creativity and experience resulting in effective solutions to many emerging environmental issues,with A&WMA an important catalyst to this success.

Effective programming can help us achieve all fourof our Association’s strategic goals by: meetingmembers’ needs and increasing membership value(Goal 1); and advancing environmental knowledge(Goal 2); thus building global awareness ofA&WMA (Goal 3); and ensuring the organization’scontinuity and sustainability (Goal 4).

Next StepsIn order to further expand and coordinate ourlearning opportunities, I have asked President-ElectSara Head to chair a new Program DevelopmentTaskforce (PDT), with Rick Sprott as vice chair. ThePDT includes the Chairs (or designees) of the fourA&WMA Councils and four key Committees(Membership, Finance, Partnerships, and Publica-tions). The purpose of this taskforce is to take thelead in promoting collaboration between the fourCouncils and the major standing Committees ofthe Board. Their primary charge is to generate relevant, timely, and member-centric specialty conferences, workshops, and professional devel-opment programs that add value to membership,align with our mission statement, and provide sustainable programming revenues to assist inmaintaining our ability to service the industry.

Please give this taskforce and the Councils your fullsupport. I am excited about our future!

emawma.org

em • message from the president

4 em april 2012Copyright 2012 Air & Waste Management Association

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CALL FOR ABSTRACTS! • DEADLINE IS APRIL 13, 2012

The Conference provides a forum for the discussion of state-of-the-art technical information, regulations, and public policy on thermal treatmenttechnologies and their relationship to air emissions, greenhouse gases, and climate change.

Invited and contributed papers will address approaches to safely managingwaste streams amenable to thermal treatment processes, and evaluate associated costs, risks, and impacts. Abstracts of 250 words or less shouldbe submitted to Carrie Hartz at [email protected]. For more information visit the conference Web site.

Sponsorship and exhibit opportunities are available

CONFERENCE LOCATIONJW Marriott New Orleans +1- 504-525-6500 Hotel Rate: $131

HOTEL CUTOFF/REGISTRATION DEADLINESeptember 24, 2012

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IT3HWC

31st International Conferenceon Thermal Treatment Technologies & HazardousWaste Combustors

October 22-24, 2012 • New Orleans, LA


the fourth year may be available in situations wheregeneration from a retiring unit is needed to maintainreliability while other units install controls. EPA’s guid-ance raises questions about the process for coordi-nating with utility reliability experts in addressingthese issues, while implying that some compliancestrategies—especially those involving transmissionupgrades, new natural gas pipelines or new off-siteunits—might not be approved for an extension.

The final utility MACT rule provides little relief orcertainty for units that may need more than fouryears for compliance. EPA’s Office of Enforcementand Compliance Assurance issued a nonbindingmemorandum,1 stating that only for the limitedsubcategory of “isolated instances in which the deactivation or retirement of a unit or a delay in installation of controls due to factors beyond theowner’s/operator’s control could have an adverse,localized impact on electric reliability that cannotbe predicted or planned for with specificity at thepresent time.” EPA offers the option of a U.S. CleanAir Act Section 113(a) administrative order (AO),allowing one additional (a fifth) year. EPA adds thatit “does not intend to seek civil penalties for violat-ing the MATS [Mercury and Air Toxics Standards]that occur as a result of operation for up to oneyear in conformity with an AO.”

Although EPA “believes that there are likely to befew, if any, cases in which it is not possible to mitigate a reliability issue within four years,” EEI believes that this AO approach is too limited inscope and has other downsides. A company wouldneed to negotiate for a potential fifth year to complyand be subject to possible citizen suits and financialpenalties, as well as operating limits. Moreover, thememorandum also indicates that the companywould not know whether it would receive an AOfrom EPA until after the compliance deadline haspassed. The compliance timing issue will continueto be debated among affected sources and federaland state agencies. em

em • cover story

Utility and Boiler MACTThis month, EM focuses on the final electric utility Maximum Achievable Control Technology

(MACT) and proposed industrial boiler MACT rules to address hazardous air pollutants, with

six articles and perspectives.

Gina McCarthy, Assistant Administrator for Air andRadiation at the U.S. Environmental ProtectionAgency (EPA), kicks it off with an overview of bothrules. Bob Bessette of the Council of IndustrialBoiler Owners—a trade association of boiler own-ers, architect-engineers, universities, and related

equipment manufacturers rep-resenting 20 major industrialsectors—provides an industryreaction to the proposedboiler MACT. The other fourauthors react to the final utilityMACT: Ann Weeks of theClean Air Task Force—a non-profit environmental organi-zation; Eric Svenson, of theelectric power corporationPublic Service EnterpriseGroup (PSEG); John McManusand colleagues of the electricpower company American

Electric Power; and Eugene Trisko, representing theUnited Mine Workers of America. EM sincerelythanks the authors for their interesting and informative contributions.

Among the most contentious issues for both rules isthe timeline for compliance. The Edison Electric In-stitute (EEI) believes that numerous units may needmore than three years to comply and that im-provements are needed to the process for obtain-ing additional time to comply. This month’s authorsare split on this issue.

In the final rule, EPA provides some guidance tostate permitting agencies regarding what wouldqualify for the one-year extension (i.e., a fourth year).At existing plants, this generally includes construc-tion, permitting, labor, procurement or resourcechallenges to installing controls, and staggering con-trols for onsite replacements. However, EPA limitedthe availability of a fourth year for the constructionof new off-site generating units or transmission up-grades to situations where electric system reliabilitywould be harmed if a unit were retired; in addition,

Reference1. See www.epa.gov/compliance/

resources/policies/civil/erp/mats-erp.pdf.

John D. KinsmanSenior Director, EnvironmentEdison Electric [email protected]

John is a long-time member of EM’s Editorial Advisory Committee.

Workshop Topics: • Water Treatment

• Water Reuse and Recycle

• Water Sourcing and Logistics

• Wastewater Disposal

The workshop will focus on the engineering design and

in-the-field implementation of water use and reuse activities.

Additionally it will bring together experts to discuss current

water management technologies and processes utilized to

address water use and impacted water disposal.

Save the Date

Shale Oil and Gas E&P – Water Challenges and Opportunities

November 1st and 2nd, 2012 Pittsburgh, PA

AIChE/A&WMA Joint Workshop

For more information go to http://www.aiche.org/conferences/calendar/2012.aspx

© 2012 AIChE 7245a • 03.12


em • feature

by Gina McCarthy

Gina McCarthy is AssistantAdministrator for Air and Radiation at the U.S. Environ-mental Protection Agency.

The U.S. Environmental Protection Agency (EPA) has made significant progress reducing harmful

pollution, protecting public health, and cleaning up our nation’s air. Last year ended with two

important actions that will significantly reduce toxic air pollution from power plants, industrial

boilers, and solid waste incinerators.

MATS and Boiler RulesPractical, Data-Driven Standards


These actions, issued under the U.S. Clean Air Act(CAA) Section 112 (129 for the incinerator rule),are data-driven and rely on proven, widely avail-able pollution control technologies to cut harmfulemissions of mercury, arsenic, chromium, nickel,acid gases, particle pollution, and sulfur dioxide.Sections 112 and 129 of the CAA require EPA toset technology-based standards for specific air pollutants from certain industrial categories, at levels that reflect those already achieved by thebest performing sources and using the best available data. Together, these actions provide billions of dollars in health benefits for the Ameri-can people and thousands of opportunities forAmerican workers to install and operate pollutioncontrols.

Mercury and Air Toxics StandardsOn December 16, 2011, EPA finalized the Mercuryand Air Toxics Standards (MATS)—a rule that hasbeen 20 years in the making. MATS is the first national rule to set standards for emissions of toxicair pollutants from new and existing coal- and oil-fired power plants. MATS will help remove toxic pollution like mercury, arsenic, and acid gases fromthe air we breathe, prevent premature deaths, andreduce the number of cases of aggravated asthmaamong children. The estimated value of the healthbenefits from these standards total $37 – $90 billioneach year. The estimated annual costs of this finalrule are $9.6 billion, which means that for everydollar spent to meet the standards, Americans willsee up to $9 in public health benefits.

Table 1. Emission limitations for coal-fired and solid oil-derived fuel-fired electricity generating units (EGUs).

Subcategory Filterable Particulate Matter Hydrogen Chloride Mercury

Existing unit designed for 0.030 lb/MMBtu 0.0020 lb/MMBtu 1.2 lb/TBtunot low rank virgin coal (0.30 lb/MWh) (0.020 lb/MWh) (0.0130 lb/GWh)

Existing unit designed for 0.030 lb/MMBtu 0.0020 lb/MMBtu 4.0 lb/TBtua

low rank virgin coal (0.30 lb/MWh) (0.020 lb/MWh) (0.040 lb/GWha)

Existing – integrated gasification 0.040 lb/MMBtu 0.00050 lb/MMBtu 2.5 lb/TBtucombined cycle (IGCC) (0.40 lb/MWh) (0.0050 lb/MWh) (0.030 lb/GWh)

Existing – Solid oil-derived 0.0080 lb/MMBtu 0.0050 lb/MMBtu 0.20 lb/TBtu(0.090 lb/MWh) (0.080 lb/MWh) (0.0020 lb/GWh)

New unit designed for not low 0.0070 lb/MWh 0.00040 lb/MWh 0.00020 lb/GWhrank virgin coal

New unit designed for coal low 0.0070 lb/MWh 0.00040 lb/MWh 0.040 lb/GWhrank virgin coal

New – IGCC 0.070 lb/MWhb 0.0020 lb/MWhd 0.0030 lb/GWhe

0.090 lb/MWhc

New – Solid oil-derived 0.020 lb/MWh 0.00040 lb/MWh 0.0020 lb/GWh

Notes: In some cases, affected units may comply with either an input-based standard or an output-based standard, shown in parentheses below the input-based standard.lb/MMBtu = pounds pollutant per million British thermal units fuel input; lb/TBtu = pounds pollutant per trillion British thermal units fuel input; lb/MWh = pounds pollutant per megawatt-hourelectric output (gross); lb/GWh = pounds pollutant per gigawatt-hour electric output (gross)a Beyond-the-floor limit. The MACT floor for this subcategory is 11.0 lb/TBtu (0.20 lb/GWh); b Duct burners on syngas; based on permit levels in comments received; c Duct burners on naturalgas; based on permit levels in comments received; d Based on best-performing similar source; e Based on permit levels in comments received

That Protect Public Health


MATS applies to coal- and oil-fired power plantsthat are larger than 25 megawatts that sell powerdistributed through the national grid to the public.This covers approximately 1,400 existing units—1,100 coal-fired units and 300 oil-fired units atabout 600 power plants. EPA expects most facilitieswill comply with this rule through a range ofproven and cost-effective strategies, including theuse of existing emission controls, upgrading emis-sion controls, installing new pollution controls, andswitching fuels.

Practical Standards Power Plants Can MeetMATS sets numeric emissions limits for most toxicair pollutants and work practice standards for organic air toxics. In some cases, the standards are “surrogates” for other pollutants (e.g., an hy-drogen chloride emissions limit to control all acid

gases). Where appropriate, sources have flexibilityto choose whether a primary standard or an alter-nate standard is best for them. The final MATS rulealso sets separate mercury requirements for twosubcategories of coal units: mine-mouth units designed for and burning low rank, virgin coal witha calorific value less than 8,300 Btu/lb; and all othercoal-fired units. The rule sets separate standards forthree subcategories of oil-fired electric generatingunits: limited-use, non-continental, and all otherunits (see Tables 1 and 2).

After EPA considered the information and addi-tional data from more than 900,000 public com-ments on the proposed rule, the agency adjustedsome aspects of the rule. As a result, though theapproach and methodology remain the same, theagencyadjusted some emissions limits, including

History of Power Plants and Air Toxics

1990 Congress amended the U.S. Clean Air Act (CAA). The amendments required EPA to issue stan-dards to reduce emissions of air toxics, also called hazardous air pollutants, from many sources,and to study whether to do so for power plants.

1998 EPA sent the results of that study in a report to Congress.

2000 EPA listed power plants for regulation under the air toxics provisions of CAA Section 112, which addresses the National Emission Stan-dards for Hazardous Air Pollutants (NESHAP) and Maximum Achievable Control Technology (MACT) programs, among others. EPAdetermined it was “appropriate and necessary” to regulate emissions of air toxics from power plants, triggering CAA requirements.

2005 EPA reversed its earlier power plant air toxics determination and issued the Clean Air Mercury Rule (CAMR), which regulated mercuryfrom power plants through a cap-and-trade program under CAA Section 111, the New Source Performance Standards (NSPS) program.

2008 The U.S. Court of Appeals for the D.C. Circuit vacated EPA’s action removing power plants from the Section 112(c) air toxics sourcecategory list and vacated CAMR.

2011 Under consent decree, EPA proposed the Mercury and Air Toxics Standards (MATS) under Section 112 on March 16, and signedthe final MATS on December 16.

2012 The final MATS rules are published in the Federal Register on February 16.

Table 2. Emission limitations for liquid oil-fired EGUs.

Subcategory Filterable PM Hydrogen Chloride Hydrogen Fluoride

Existing – Liquid oil-continental 0.030 lb/MMBtu 0.0020 lb/MMBtu 0.00040 lb/MMBtu(0.30 lb/MWh) (0.010 lb/MWh) (0.0040 lb/MWh)

Existing – Liquid oil-non-continental 0.030 lb/MMBtu 0.00020 lb/MMBtu 0.000060 lb/MMBtu(0.30 lb/MWh) (0.0020 lb/MWh) (0.00050 lb/MWh)

New – Liquid oil – continental 0.070 lb/MWh 0.00040 lb/MWh 0.00040 lb/MWh

New – Liquid oil – non-continental 0.20 lb/MWh 0.0020 lb/MWh 0.00050 lb/MWh

Notes: In some cases, affected units may comply with either an input-based standard or an output-based standard, shown in parentheses below the input-based standard.


using filterable particulate matter as a surrogate for the metal toxics limit; clarified definitions forsubcategories; simplified and improved monitoringprovisions for clarity, consistency, and increasedflexibility; and provided an alternative complianceoption for sources that plan to comply by averagingacross multiple units within the same facility.

Facilities will have up to four years to meet the stan-dards, providing affected plants with enough timeto install health-protective controls while continu-ing to meet the nation’s needs for reliable, afford-able energy. If localized reliability issues arise, EPAhas also issued an enforcement policy that providesa well-defined path for units to obtain a schedule toachieve compliance within an additional year if theyare shown to be necessary to maintain electric reliability.

Utilities strive to provide reliable and affordableelectricity to all Americans. We share this samegoal, as I discussed in greater detail in EM last fall(EM, October 2011, p. 6). For 40 years, EPA hasensured clean air to the American public withoutimpacting electric reliability. MATS will not changethat. EPA’s analysis, as well as other analyses,

including one from the U.S. Department of Energy(DOE), show that the rule is unlikely to have anysignificant effect on electricity reliability.

Boiler MACT and Incinerator RulesOn December 2, 2011, EPA proposed changes toCAA standards for boilers and certain incineratorsthat EPA had issued in March 2011. When EPA issued those final standards in March, the agencyalso announced it intended to reconsider the stan-dards to seek additional public review and commentand ensure full transparency. In December 2011,as a result of our reconsideration, EPA proposedupdated standards that are based on extensiveanalysis, review, and consideration of data andinput from states, environmental groups, industry,lawmakers, and the public, and would achieve significant reductions in toxic air pollutants. Thenewly proposed standards maintain significanthealth benefits, are based on the best availabledata and methodologies, provide additional flexi-bility as data warrants and the law allows, and cutthe cost of implementation by nearly 50% fromthe original 2010 proposed rules.

The proposed reconsidered standards would cut

A&WMA’s Annual Conference & Exhibition offers the most up to date information on shale oil and gas exploration and production.

This four day conference offers a variety of technical sessions that address technical and policy issues associated with air, water, and waste in connection with shale oil and gas exploration and production.

Don’t miss this opportunity to hear from top industry experts!

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105TH ANNUAL CONFERENCE

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Shale Oil and Gas Exploration and Production Topics

June 19-22, 2012

Join the Air & Waste Management Association and the American Institute of Chemical Engineers for an in-depth look at recent air emissions permitting and compliance strategies.

Tuesday, May 1, 201212:00 - 1:30 P.M. Eastern

This 90-minute webinar is designed to help shale gas developers respond to stricter government regulations, permitting policies, best practices and more public participation in the administration process.

Hear directly from leading industry consultants and, counsel and pose questions via electronic chat.

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Moderated by Dan Mueller, P.E. of Zephyr Environmental Corporation

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Shale De

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evelopment:

d


emissions of harmful pollutants, including mercury,particle pollution, sulfur dioxide, dioxin, lead, andnitrogen oxides. The standards would preventthousands of premature deaths, heart attacks,and cases of aggravated asthma each year. Bene-fits from the rules would total $28 – 68 billion eachyear, far outweighing annual costs of $2.3 billion.

There are approximately 1.5 million boilers in theUnited States. The vast majority—1.3 million—arelocated at small facilities and emit too little to becovered by these standards. That leaves just over200,000 sources covered under the boiler pro-posals. Of the 200,000, almost 195,000 boilerswould be required to follow work practice stan-dards to limit emissions. This leaves only 5,500—less than 1% of all boilers—that are expected toneed pollution controls to limit their emissions. Thatmeans more than 99% of boilers in the countryare either clean enough that they are not coveredby these standards or will only need to conductwork practice standards to comply, including routinemaintenance and tune-ups.

The Right Standards for the Right BoilersBecause of the diverse and complex nature of thesesources, EPA has worked extensively with stake-holders to develop these strong standards. Thisinput has helped EPA better understand thesesources, so that the right standards are applied to theright boilers. This doesn’t mean that the standardsare weaker, but it does mean that this real-worlddata has helped us propose affordable, practicalregulations that provide vital health benefits.

Some of the December 2011 proposed changesfor major source boilers (the reconsidered BoilerMACT) include:

• Creating new subcategories for light and heavyindustrial liquids;

• Setting new emissions limits for particulatematter that are different for each design-basedsubcategory;

• Setting new emissions limits for carbon monoxide; • Allowing alternative total selective metals emis-

sion limits to regulate metallic air toxics instead ofusing particulate matter as a surrogate;

• Implementing work practice standards to reflectlimitations of method detection levels for dioxin;

• Increasing flexibility in certain compliance monitoring situations;

• Revising emissions limits for units located out-side the continental United States; and

• Continuing to allow units burning clean gases toqualify for work practice standards instead of numeric emissions limits.

In Spring 2011, shortly after issuing the Marchfinal standards for major source boilers and certainincinerators, EPA issued an administrative stay oftheir effective dates, which a federal court vacatedin January 2012. To address resulting concerns ofthe regulated community, EPA has informedsources that the agency will not enforce certain notification requirements in the March 2011 rules.

2012 and BeyondThe progress we made in 2011 lays the ground-work for realizing the important public health pro-tections of these actions. This spring, EPA will takesteps to finalize the changes to the boiler and incinerator standards. EPA will continue to work withall interested stakeholders and other agencies to design strategies and tools that will ensure smoothimplementation and help owners and operators understand the standards and their cost- and energy-saving features. For example, EPA recently has beenaddressing concerns about reliability with a range ofstakeholders, including the National Association ofRegulatory Utility Commissioners (NARUC), theNorth American Electric Reliability Corporation(NERC), regional transmission organizations, andthe Federal Energy Regulatory Commission.

For the boiler rules, EPA also has been working withDOE and the U.S. Department of Agriculture to pro-vide technical assistance to help boilers burn morecleanly and more efficiently. Together, these standardsprovide a common-sense approach to improving airquality and protecting public health. em

To Learn More

• The final Mercury and Air Toxics Standards (MATS) rule is available at 77 Fed. Regist. 9304 and online at www.epa.gov/mats.

• More information regarding resource adequacy and reliability analyses is available online at www.epa.gov/ttn/atw/utility/revised_resource_adequacy_tsd.pdf.

• The MATS Enforcement Response Policy is available online athttp://cfpub.epa.gov/compliance/resources/policies/civil/erp/.

• The reconsideration proposals for the Boiler Maximum Achievable ControlTechnology (MACT), boiler area source and commercial and industrial solidwaste incinerator rules are available at 76 Fed. Regist. 80598, 76 Fed. Regist.80532, and 76 Fed. Regist. 80452, respectively, and online at

www.epa.gov/airquality/combustion/.


em • washington report

From fiscal year 1990 throughOctober 2010, the U.S. Envi-

ronmental Protection Agency(EPA) collected from poten-tially responsible partiesapproximately $4 billion infunds that were placed in

special accounts, according toa Government Accountability

Office (GAO) report. Approximatelyhalf of the funds are still available to be obligated for futurecleanups, according to the report, Superfund: Status of EPA’s Effortsto Improve Its Management and Oversight of Special Accounts.The remaining funds already have been obligated, but not all ofthe obligated funds have been disbursed, the report said.

Special accounts are set up to hold funds resulting from settle-ments reached with potentially responsible parties. They are interest-earning, site-specific special accounts within the TrustFund to pay for site cleanups. These accounts provide resourcesin addition to annual appropriations to clean up sites. In its review, GAO looked at the status of Superfund special accountsand the extent to which EPA’s headquarters and its 10 regionaloffices have implemented processes and policies to improve the

monitoring and management of the funds. The organizationmade no recommendations in its report. The review was requested by Sen. James Inhofe (R-Okla.).

GAO said EPA has plans to obligate nearly all the available fundsin special accounts over the next 10 years. However, special account funds to be obligated are estimates rather than com-mitments, and the planned use of funds often changes as sitecircumstances warrant, the report said. As of October 2010, ofthe $1.9 billion funds that EPA had obligated for Superfundcleanup expenses, $1.6 billion had been disbursed.

In 2006 and 2009, the EPA inspector general made recom-mendations for better management of these accounts. EPA hasfollowed some of these recommendations, the GAO report said.For example, it added a screen in the agency’s Superfund data-base that enables EPA regions to enter special account planningdata into specific data fields and create reports, so officials canmonitor the special account balances against planned obligationsfor ongoing and future site-specific response activities. In another improvement, EPA increased oversight of special accounts,while designating a national special accounts coordinator, GAO said. em

Revised Study Puts National Recycling Rate at 34.1%EPA has revised its 2010 study of municipal solid waste generation, recycling, and disposal, using a more consistent methodologythat brought the recycling rate of polyethylene terephthalate (PET) containers up to 29.2% from 21% and increased the nationalrecycling rate to 34.1% from 34%. According to the revised study, the recycling rate of selected consumer electronics also fell from 26.6% to 19.6%.

EPA said the figures represent an effort to standardize the agency’s methodologiesover multiple years. The agency updated the PET recycling rate to include caps, lids,and other materials that had been excluded from the initial report. For the originalreport, EPA used a consumer electronics recycling rate based on a smaller groupof electronics than the agency had used in the Electronics Waste Management inthe United States Through 2009 report. EPA used a broader methodology fromprevious municipal solid waste characterization studies, which included more typesof electronics, to generate the revised recycling rate.

Originally released in November, the 2010 study found that Americans produced249.9 million tons of waste in 2010 and recycled or composted 85.1 million tons ofthat material. em

Compiled by Mark Williams Bloomberg BNA, www.bna.com. Note: All amounts in U.S. dollars.

EPA Has $4 Billion in Special Accounts for Superfund Cleanups


em • feature

by Robert D. Bessette

Robert D. Bessette is president of the Council of Industrial Boiler Owners(CIBO) in Warrenton, VA. E-mail: [email protected].

The U.S. Environmental Protection Agency’s (EPA) latest variation of its Boiler Maximum

Achievable Control Technology or “Boiler MACT” standards improved on the March 2011 final

rule, but are still overly punishing to coal and oil-fired boilers.

Reconsidered BoilerMACT Rule Needs Some


Council of Industrial Boiler Owners (CIBO) membersown or operate industrial, institutional, and com-mercial boilers that power manufacturing plants,universities, and commercial facilities. The majorsource rule regulates 14,000 boilers; EPA projectsthat 1,680 of those will need to install additionalemission controls to meet the standards. CIBOhopes that EPA, in response to comments on theproposed reconsidered rule, will address severalsignificant elements—a few of which are noted here.

As we work through the details of this most recentproposal, two points about standard-setting forhazardous air pollutants (HAPs) bear noting. First,as sources achieve increasingly lower emissions,EPA standards must reflect correspondingly greaterrefined consideration of differentials among boilerdesign, fuels, and other variables that directly affectachievability of the standards. Second, Congressshould re-set the stage for these standards to ensurethat they are achievable in practice as required bythe clear text of the U.S. Clean Air Act and thatsources will be able to meet the compliance deadline.

Achievability Is FundamentalTo its credit, EPA has adjusted some elements ofthe March 2011 rule that simply made no sense,including, for example, duplicative monitoring requirements. However, work remains to be donewhere it really counts: achievability. The first BoilerMACT rule (issued in 2004) set a standard for hydrogen chloride (HCl) at 0.09 lb/MMBtu. Today,in the 2012 rule, EPA is talking about HCl con-trolled down to 0.022 lb/MMBtu. We have comea long way in reducing emissions, but such fine-tuning means that many once-minor aspects of theboiler operation now must be considered by EPAwhen analyzing whether standards are achievable.For some pollutants for some boilers, EPA has notyet done this fine-tuning.

One example is the particulate matter (PM) standardfor some boilers. The PM limit for new circulatingfluidized-bed boilers (CFBs) is 0.0011 lb/MMBtu,which cannot be met by sources with even verynew CFBs. Existing stoker boilers must meet a limitof 0.028 lb/MMBtu. This standard is set so lowthat sources, if they can comply, are left with almostno compliance margin and under the best circum-stances will risk noncompliance.

Another example is the carbon monoxide (CO)standard. In the past, with less sophisticated controls,CO emissions were assumed to roughly corre-spond with organic HAPs, and a CO limit was setas a surrogate for those HAPs. Now, with much refined measurement and aggressive CO limits,the correlation between CO and organic HAPsneeds to be revisited. EPA did that work for the utility MACT and concluded that, in fact, CO emis-sions may not correlate so directly with HAPs thatare also the result of incomplete combustion. EPAalso concluded that those HAP emissions measuredwere below test method detection levels a majorityof times. Even as sources struggle to meet very lowCO limits, achieving those reductions is not reduc-ing organic HAPs in a majority of cases. In otherwords, even if sources can achieve the CO limit,the rule is not achieving the intended reduction oforganic HAPs.

Congress Should Re-Set the Boiler MACT ProcessEPA has the legal tools to set achievable standards.If EPA sets standards—as it has for some coal-firedsources—that are effectively not achievable, then itappears the agency is using environmental rule-making, in keeping with EPA Administrator Jackson’sstated goal, to price coal out of the market.

Under these circumstances, Congress should actto give EPA clear direction that MACT standardsmust reflect the emission limits that are achievableby real sources under real and variable operatingconditions. Congress could also give EPA directionthat the cost of achieving the standards should beconsidered relative to the human health and envi-ronmental benefits that would be derived from reductions of the HAPs that are the focus of theNational Emission Standards for Hazardous Air Pol-lutants (NESHAPS) provisions. An act of Congresswould also ensure sources will have the full periodof time they need to come into compliance withthe rules and help mitigate future litigation becauseof differences in interpretation of the rules by thecourts, litigants, and EPA. em

In other words,

even if sources

can achieve the

CO limit, the rule

is not achieving

the intended

reduction of

organic HAPs.


awma.org

em • feature

by Ann Weeks

Ann Weeks is senior counsel for the Clean AirTask Force, Boston, MA. E-mail: [email protected].

Much noise has been made since the U.S. Environmental Protection Agency’s (EPA) Mercury and

Air Toxics Standards (MATS) rule was proposed, about the potential for reliability issues associ-

ated with its implementation. By contrast, multiple studies1 of the proposal strongly suggested

the likelihood of an orderly transition to full compliance, due to existing U.S. federal statutory

compliance extension tools that can be brought to bear as needed. Moreover, actual experience

with pollution control installations between 2005 and 2010, in order to meet the EPA’s Clean Air

Interstate Rule and various state air quality and air toxics rules, did not raise reliability issues even

when 25 gigawatts of pollution controls were added in a single year.2

First Impressions:

In any event, such concerns should be put to restfor good with the publication of EPA’s final MATSrule.3 It is weaker, in several respects, than the proposal, which should make it easier for existingcoal-fired power plant owners to implement its requirements. As one example, the final rule includesless stringent standards for particulate matter (thesurrogate for heavy metals) than proposed, likelyrequiring less costly control technology applications.

Additionally, President Obama issued a memoran-dum to EPA accompanying the release of the finalMATS rule, describing the expectation that MATSwill be implemented using demonstrated, existingcontrol technologies and directing EPA to invokeavailable flexibility under the U.S. Clean Air Act, including a fourth year for compliance by existingsources, where justified.4 EPA is directed to continueengaging with the U.S. Department of Energy (DOE),


Administration Directs Flexible Implementation of MATS Rule

the U.S. Federal Energy Regulatory Commission(FERC), state utility regulators, and other stake-holders, including the public, to promote early coordinated planning for MATS rule implementa-tion. A recent FERC public forum on reliability andthe environment held at the National Association of Regulatory Utility Commissioners meeting inWashington, DC, on February 7, 2012, advancesthat process.

Despite these additional flexibilities beyond theproposal, MATS is still expected to achieve mone-tized health benefits 3–9 times greater than thecosts of compliance. That benefit-cost comparisondoes not come close to illustrating the full value ofthese first-ever existing coal-fired power plant airtoxics emissions limits, as there will also be signifi-cant benefits to fish, wildlife, and habitats, due tothe full implementation of the MATS rule. In orderto ensure that these benefits are actually achieved,any reliability-mandated extensions in compliancetimes for the MATS rule must be accompanied by

agreements limiting the run time for uncontrolledor under-controlled units only to the times actuallyneeded to preserve system reliability.5

It’s safe to say, no one likes such agreements—those of us who are concerned about public healthand the environment do not want any continuedoperation of uncontrolled or under controlled unitspast the statutory compliance deadlines, and relia-bility-only must-run agreements are also disfavoredby regulators and consumers because they costmore than unlimited permission to run an uncon-trolled and less costly unit. The need for them can beavoided, however, if industry spends its resourcesand gives its attention to early and coordinated implementation planning, rather than seeking tooverturn EPA’s MATS rule. Will that happen? em

awma.org

References1. See for example: Ensuring a Clean, Modern Electric Generating Fleet

while Maintaining Electric System Reliability, Fall 2011 Update; M.J.Bradley and Associates & Analysis Group, November 2011; availableonline at www.mjbradley.com/sites/default/files/ReliabilityUpdateNovember202011.pdf (accessed January 2012); EPA’s Regulation ofCoal-Fired Power: Is a ‘Train Wreck’ Coming?; James E. McCarthy &Claudia Copeland, Congressional Research Service, August 8, 2011;available online at www.fas.org/sgp/crs/misc/R41914.pdf (accessedJanuary 2012).

2. Resource Adequacy Implications of Forthcoming EPA Air Quality Reg-ulations; U.S. Department of Energy, December 2011; available on-line at http://energy.gov/pi/office-policy-and-international-affairs/office-policy-and-international-affairs/office-policy—11.

3. Mercury and Air Toxics Standards (MATS) Final Rule; 76 Fed. Regist.9304 (Feb. 16, 2012).

4. Presidential Documents, Memorandum for the Administrator of theEnvironmental Protection Agency, “Flexible Implementation of theMercury and Air Toxics Standards Rule”; 76 Fed. Regist. 80,272 (Dec.27, 2011).

5. Hanger, J. Reliability-Only Dispatch; Clean Air Task Force, October2011; available online at www.catf.us/resources/publications/files/Reliability-Only_ Dispatch.pdf (accessed January 2012).


em • feature

by Eric B. Svenson, Jr.

Eric B. Svenson, Jr., vicepresident of policy and environment, health, andsafety for Public Service Enterprise Group (PSEG) Inc.,Newark, NJ. E-mail:[email protected].

PSEG is a publicly traded(NYSE: PEG) diversified energy company with morethan $29 billion in assets.PSEG’s wholesale energysupply business includes nuclear, natural gas, coal, and oil-fired generating units, with a combined capacity of approximately13,500 megawatts.

Last December, U.S. Environmental Protection Agency (EPA) Administrator Lisa Jackson unveiled

the Mercury and Air Toxics Standards (MATS), which will establish for the first time national limits

on mercury and other toxic air pollutants from coal- and oil-fired power plants. This clean air rule

does not come out of the blue, but has been more than two decades in the making. No one

disputes that mercury is harmful to human health or that the technology is available now to

dramatically reduce mercury and other harmful emissions from coal- and oil-fired power plants.

Action is long overdue, and our industry can comply without compromising reliability.

Mercury and Air Toxics Standards:

From the beginning, Public Service EnterpriseGroup (PSEG) Inc. has been supportive of EPA actionon this rule, and we are well positioned to complybecause of the investments we have made in ourfleet. PSEG invested $1.5 billion to install a rangeof advanced pollution controls at our coal-firedpower plants, reducing emissions of mercury andacid gases by 90% or more. These projects createdjobs for 1,600 construction workers and addedpermanent positions at our plants.

PSEG is not alone—many utility companies havemade similar investments. In fact, approximately60% of the coal-fired capacity in the United Stateshas scrubbers installed or under construction, andclose to 20% of the total coal-fired capacity hasmercury-specific controls installed or planned. It’stime for the plants that are operating without mod-ern controls to step up to the plate. The MATS ruleprovides a consistent set of national standards toguide future investment decisions.

With any major environmental rule, the devil is inthe details. EPA’s draft rule had several provisions thatutility companies believed were overly burdensomeor needed improvement. Fortunately, EPA was responsive to the industry’s concerns and improvedthe final rule in a number of important respects. Forexample, the final rule reduced the frequency ofemissions testing, simplified the compliance require-ments, and eliminated most of the fuel testing requirements, while preserving the environmentalintegrity of the rule. Other industry concerns werealso addressed, including the use of work practicestandards during periods of startup and shutdownand the approach to regulating metals.

In the final rule, EPA has also provided additionalflexibility in terms of the compliance schedule. Existing units will have at least three years to comply.EPA expects a fourth year to be broadly availableif a unit needs more time to install controls, if newgeneration is being constructed on site but is notyet completed, or if a retiring unit is needed for reliability purposes and new generation capacity ortransmission upgrades are needed to maintain reliability. EPA has also indicated that a fifth year isavailable if a unit is critical for reliability. Due to suchflexibility, a large Midwest coal utility recently announced that it will retire less than half of thecoal-fired capacity it previously planned to retire.

We believe our industry is capable of meeting theMATS rule, while maintaining electric system relia-bility. The U.S. bulk power system, at an aggregatelevel, has adequate spare capacity to absorb the retirement of uncontrolled plants, most of whichare smaller, inefficient units. Companies were alreadymaking power plant retirement decisions inde-pendent of the MATS rule due to the reduced demand for electricity and depressed natural gasprices for the foreseeable future. Moreover, theelectric industry has a proven track record of delivering generation and transmission resourceswhere necessary and has experience in coordinat-ing effectively with planning authorities to addressreliability concerns.

In short, the MATS rule makes clear what the indus-try needs to do. The rule provides the certainty tomove forward with investments that will modernizeAmerica’s electric power infrastructure and create jobs.It’s time to make the most of this opportunity. em


awma.org

Photo courtesy of PSEG.

The Right Step for Our Nation and Industry

We believe our industry is

capable of meetingthe MATS rule,

while maintainingelectric system

reliability.


em • feature

by John M. McManus,Frank E. Blake, and Paul M. Jackson

John M. McManus is vicepresident, Frank E. Blake isa senior engineer, and PaulM. Jackson is an engineer,all with American ElectricPower (AEP), Columbus, OH. E-mail:[email protected].

American Electric Power (AEP) has provided affordable, sustainable, and reliable electricity for

more than 100 years, based, in large part, on the benefits of coal-fueled generation. With

one of the nation’s largest fleets of coal-fueled generating stations, operation of the largest

transmission system in the United States, and the company’s leadership in technology

development, AEP has extensive knowledge of the technical capabilities of this generating

technology, the practical limits for building emission controls, and the corresponding risks

such actions can impose for compliance, ratepayers, and grid reliability.

A Utility PerspectiveAir Toxics Standards


From this position, AEP provided extensive com-ments on the proposed rule and has been a leaderin the public dialogue about the impact of the finalMercury and Air Toxics Standard (MATS). AEP hasexpressed numerous concerns and identified anumber of mechanisms through which the U.S.Environmental Protection Agency (EPA) can incor-porate flexibility into the final rule and reduce thenegative economic and reliability impacts—all whileachieving the same level of emission reductions.

It is important to understand that the MATS rule isfundamentally different from the broad regionaland national emissions reductions programs thatmost electric generating units have been operatingunder for the past 20 years. With the Title IV sulfurdioxide allowance program, Congress ushered inan era of flexible, market-based emission reductionprograms that enabled the continued operation ofmost of the existing coal-fired generating fleet. EPAutilized this same approach in the NOx SIP Call(for oxides of nitrogen emissions), the Clean Air Interstate Rule (CAIR), the Clean Air Mercury Rule(CAMR), and, most recently, in the Cross-States AirPollution Rule (CSAPR). All of these rules werebased on flexible mechanisms for compliance thathave allowed significant emission reductions to beachieved with manageable economic impacts. (Itshould be noted that CAIR was remanded to EPAfor revision, but is currently in effect with the stayof CSAPR, and CAMR was vacated.)

With the MATS rule and programs like regionalhaze, EPA is implementing parts of the U.S. CleanAir Act through a command-and-control regula-tory regime that severely limits compliance optionsto installing emissions controls or shutting down.There is little middle ground. As a result, Americawill see for the first time widespread retirements ofcoal-fueled generating units in a relatively short period of time.

Stringent Emissions LimitsEPA made some changes in the final MATS rulefrom the proposed rule that will help reduce thecompliance challenges and costs to a degree. Thebest example is a more reasonable approach tousing particulate matter as a surrogate for non-mercury metals. However, the final emission limitsremain very stringent, especially for new sources,and pose significant technical, operational, and implementation challenges. The most significantconcern with the MATS rule is that the time allowed for implementation is insufficient for compliance strategies to be developed, regulatoryapprovals received, materials procured, and con-struction and start-up completed. This concern is

May 10-11, 2012 Atlanta, GA July 24-25, 2012Minneapolis, MN November 13-14, 2012Hartford, CT

Keep up-to-date on the latest changes and challenges for permitting requirements under the National Ambient Air Quality Standards, New Source Review, PM2.5, the 8-Hour Ozone Standard and the Greenhouse Gas Tailoring Rule.

These two-day workshops will cover permitting changes presented by both national and regional leaders in the field. Attend a workshop near you:

CATR

Greenhouse Gas

Tailoring

8 hr. OzoneStandard

TitleV

PM2.5

NSR

Register today: http://permitting.awma.org

Understanding Today’s Clean Air Act Permit Programs

on the Final Mercury and


premised on the practical time required to imple-ment compliance plans, the unit-specific design ofthe requirements, and the large number of emissioncontrol projects and unit retirements that will occurin regions primarily powered with coal.

Each coal-fueled generating unit essentially has twocompliance options: (1) install or upgrade emissioncontrols or (2) retire and perhaps replace the capacity. AEP has installed emission controls (i.e.,flue gas desulfurization [FGD] and selective catalytic reduction systems) at nine coal-fueledunits (7,800 MW) since 2003 at a cost of morethan $3.6 billion. Based on AEP’s experience, thetypical time required to complete, from initiation tooperation, emission control projects is five years fora FGD system and four years for a fabric filter par-ticulate control system. Further, the typical timelinefor developing a new natural-gas combined cyclegenerating unit also is five years.

Managing the compliance and reliability risksposed by the MATS rule compliance schedulewould be achievable if it affected only a few gen-erating units. But coal-fueled units supply approx-imately 45% of the electricity in the United States,and all of that generation is subject to the MATSrule in the same time period. AEP alone will be in-stalling emission controls on approximately 10,000MW and will be retiring more than 5,000 MW to comply with the MATS rule and other expected environmental requirements. As similarcompliance strategies are implemented by utilitiesacross the United States, the magnitude of unitsthat are simultaneously not in-service because oftie-in outages for emissions control equipment or

due to retirement creates a significant grid reliabilityrisk—not discounting the ability to even find thelabor, equipment, and capital resources to completeemission control retrofits.

The final MATS rule does provide some limited flex-ibility for implementation. The deadline for initialcompliance is three years after the effective date ofthe rule, with the option of a one-year administrativeextension (a fourth year) from the permitting authority. EPA expects broad application of the administrative extension, but the actual applicabilityremains to be determined. EPA also offers the option for using an enforcement order to obtainan additional one-year extension (a fifth year) forunits that present serious reliability risks. EPA expectsthe need for this extension to be very small or“non-existent.”

That remains to be seen. The process and timingfor obtaining the additional extension via an enforcement order will be challenging and createssignificant compliance planning uncertainty. Theapproval process will involve extensive coordina-tion with regional transmission organizations andstate utility commissions that must consider reliabilityand cost issues in context with evolving compliancestrategies being implemented across the country. Itwill be critical that this process be well-coordinatedto avoid creating even greater implementationchallenges than already exist.

The Future Face of Power GenerationHow electricity is generated and used in the UnitedStates is in rapid transition. The magnitude of environmental regulations to be implemented inthe near-term, coupled with the prospect of long-term, low natural gas prices are key factors that willchange the future face of power generation in ournation. Technology advancements will transformthe generation, transmission, and use of electricityinto an ever more efficient and effective system.But overlain on this transformation are the timingand scope of more stringent environmental regu-lation across all media, which will come at significantcost. Effectively managing the implementation ofthese new requirements will be critical to managinga transition that maintains the role of affordableand reliable electricity as a driver for economicgrowth. em

How electricity is

generated and

used in the United

States is in rapid

transition.


em • canadian report

Vancouver Launches Electric Vehicle TrialThe City of Vancouver, in partnership with the Canadian and British Columbia governments, BC Hydro, and the Federation of CanadianMunicipalities, has launched an electric vehicle trial. The $800,000 Charge and Go Vancouver Trial will consist of the installation ofup to 67 Level I (110-volt) and Level II (240-volt) electric vehicle charging stations throughout the city by the end of 2013.

The project—which will provide motorists with significantly more charging options than currentlyexist and will enhance the local electric vehicle charging network—will assess the opportunities

and barriers, processes, costs, and ideal locations for the installation of electric vehiclecharging infrastructure. The charging stations will be strategically located throughout

Vancouver, based on site suitability. The price for public charging will vary depending on the location, but will be set to encourage the use of electric vehicles,while promoting public transit, walking, and cycling as the preferred modes oftransportation.

The City of Vancouver became an electric vehicle charging infrastructure leader inCanada in 2009 when it instituted a policy requiring 20% of parking stalls in new condo

buildings to be electric vehicle charging-station-ready and all new single family homes tohave dedicated electric vehicle plug-in outlets. em

Nova Scotia Gives Go-Ahead to Green Energy ProjectsThe Nova Scotia government has approved five renewable energyprojects through its Community Feed-in Tariff (COMFIT) program.The COMFIT program provides eligible applicants an estab-lished price per kilowatt hour for projects producing electricityfrom renewable resources.

The approved applicants are:• Halifax Regional Water Commission — who is proposing a

4.6-MW wind project in North Preston• Watts Wind Energy Inc., Brookfield Asset Management,

and Katalyst Wind — who are proposing a 2-MW wind projectin Bayswater

• Scotian Wind, Scotian Windfields, and WEB Wind EnergyNorth America — who are proposing a 1.99-MW wind projectin Wedgeport

• Celtic Current and Zutphen Wind — who are proposing a0.9-MW wind project in Cheticamp

• Colchester-Cumberland Wind Field Community EconomicDevelopment Corporation — who is proposing a 50-kilowattwind project at the Spiddle Hill Wind Farm near Tatamagouche

For more information on COMFIT, visit www.nsrenewables.ca. em

BC Trucking Companies to Receive$2 Million in Green RetrofitsThe British Columbia (BC) government is giving the CarbonOffset Aggregation Cooperative (COAC) $2 million to help heavyequipment operators and trucking companies green their fleets.

COAC, which currently has 25 member companies, is a market-ing cooperative that provides a framework for owners of heavyequipment and trucks to reduce operating costs, and create, aggregate, and sell carbon offsets that are produced through areduction in diesel consumption.

The funding will help COAC provide more members with low-interest loans to retrofit their heavy-duty diesel trucks andequipment. For more information on the COAC, visit www.carbonoffsetcooperative.org. em

Canadian Report is compiled with excerpts from EcoLog News and the EcoCompliance.ca newsletter, both published by EcoLog Information Resources Group, a divisionof BIG Information Product LP. For more Canadian environmental information, visit www.ecolog.com. Note: All amounts in Canadian dollars.


em • feature

by Eugene M. Trisko

Eugene M. Trisko is an attorney in private practice.He has represented theUnited Mine Workers ofAmerica (UMWA) in environmental matters formore than 25 years, and isGeneral Counsel to Unionsfor Jobs and the Environ-ment, an association of 12national labor unions. Theviews expressed here are his own. E-mail:[email protected].

The U.S. Environmental Protection Agency’s (EPA) Utility Mercury and Air Toxics Standards

(MATS) and Cross-State Air Pollution Rule (CSAPR) each require significant reductions of sulfur

dioxide (SO2) and other emissions on short, uncoordinated timetables. Every major utility

emission control program since the 1990 Title IV Acid Rain Amendments—including the

Northeast Ozone Transport Commission’s 1994 NOx Memorandum of Understanding, EPA’s

1998 NOx SIP Call, and the 2005 Clean Air Interstate Rule (CAIR) that CSAPR replaced—has

provided at least five years for initial compliance.

MATS + CSAPR The Case for Policy Coordination

Four to five years typically are necessary for thepermitting, financing, engineering, and constructionof major retrofit projects, such as scrubbers, or theinstallation of multiple emission controls for air toxics.More than 1,100 coal-based units are affected bythe basic three-year compliance deadline for MATS,including some 600 units covered by CSAPR’s2012 and 2014 deadlines. The controls needed tomeet CSAPR’s 2014 SO2 reduction targets, aver-aging 49% from 2010 levels in eastern states, willbe the same controls employed at many units toachieve the mercury, acid gas, and SO2 reductionsrequired by MATS.

In March 2010, the United Mine Workers ofAmerica (UMWA) released one of the first assess-ments of potential plant closures and job losses associated with the MATS and CSAPR rules. TheUMWA estimated that up to 56,000 megawatts(56 gigawatts) of coal-based generating capacity atunscrubbed units more than 40 years old andsmaller than 400 MW could be “at risk” of prema-ture closure.

The union calculated 54,000 direct jobs at risk inthe mining, utility, and rail transportation sectors,along with another 200,000 indirect jobs. The study

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april 2012 em 25Copyright 2012 Air & Waste Management Association

did not consider potential jobs at replacement capacity because natural gas generation requires onlya small fraction of the employees needed to supply,operate, and maintain conventional coal plants.

More than two dozen subsequent studies by WallStreet and other analysts, including Credit Suisse,FBR Capital Markets, The Brattle Group, NationalEconomic Research Associates, ICF Inc., and staffof the Federal Energy Regulatory Commissionbracketed the range of potential plant closures atroughly 30–80 GW. These estimates are signifi-cantly higher than EPA’s projections. In the finalMATS Regulatory Impact Analysis, EPA reduced itsestimate of coal plant closures to less than 5 GW.The agency’s forecasts of small potential net jobgains reflect its unrealistic assessment of plant closures, and do not consider the impacts on localcommunities of the loss of high-wage skilled jobsand reduced local tax bases.

The prospect of substantial, imminent job lossesdue to the abbreviated timetables of CSAPR andMATS led to the introduction of S. 1833, the bi-partisan Fair Compliance Act of 2011, cosponsoredby Sens. Joe Manchin (D-WV) and Dan Coats (R-IN). S. 1833 accepts the stringency of emissionreductions required by EPA’s rules, while putting bothrules on parallel five-year compliance timetables.

Manchin-Coats anticipates that additional compliancetime provides a more orderly planning process forthe retrofit of hundreds of emission controls andthe phase-out of uneconomic units, reducing

adverse employment impacts as well as risks to reliability. The legislation earned the sup-

port of six national labor unions, theBuilding & Construction Trades

Department of the AFL-CIO, and numerous energy and utility interests.

The December 2011 order by the U.S. Court ofAppeals staying the implementation of CSAPR provides Congress with a new opportunity to harmonize these two rules. While EPA sought toprovide additional flexibility in the final MATS com-pliance schedule, the process prescribed for plantowners seeking a fifth year for compliance at “reli-ability critical” units is fraught with technical uncer-tainties and legal risks. Workers at units that do notmeet “reliability critical” criteria, or that are simplyat the end of vendor supply chains, are out of luck.

Congress could adopt the basic five-year complianceformula required by Manchin-Coats in legislationcoordinating the compliance schedules of MATSand CSAPR. Such legislation could be fashionedindependent of the stay and judicial review ofCSAPR, requiring any subsequent rulemaking toprovide at least five years for compliance.

Whether the relief granted to petitioners in theCSAPR litigation is narrow or broad, interstatetransport of pollutants will be an increasingly important issue as EPA proceeds with revisions of the particulate matter and ozone standards. Workers throughout the utility, coal, and railtransport sectors would welcome a congressionaltemplate for the compliance schedules applicableto CSAPR and any subsequent transport rules. em

awma.org


awma.org

em • feature

by Dean L. Groves andDouglas C. Prentiss

Dean L. Groves, P.E., ispresident and chief executiveofficer of Fay, Spofford &Thorndike, Inc. (FST). Duringhis 38-year career, Groveshas focused on transportationplanning and environmentaldocumentation in connectionwith complex transportationprojects, and municipal engi-neering. Doug Prentiss,P.E., P.T.O.E, is principal traffic engineer with FST andis currently involved in astatewide Complete Streetsinitiative in Massachusetts.

Across the United States, towns and cities are embracing a movement, known as Complete

Streets. This is a concept that promotes the design and construction of safe and efficient

transportation networks at the local level—for all users, regardless of ability, or whether they

choose to bike, walk, ride, use mass transit, or drive.

The Complete Streets Concept Promoting Safe, Efficient, and Sustainable Transportation


The Complete Streets concept is also helpful inachieving a community’s efforts to promote sus-tainability and become more environmentally con-scious. A fully realized Complete Streets plan canimprove the local outdoor environment, includingair quality through the reduction of traffic congestion.It also serves to promote nonmotorized transport,enhanced stormwater runoff management, andadds to a community’s green spaces.

Unique Concepts and PlansThe Complete Streets concept typically providesprovisions for bicycles (e.g., a bike lane), pedestri-ans, and vehicles, all within the same right-of-way.There is no single design template for a CompleteStreets project; each concept and plan is as uniqueas the community in which it is implemented. How-ever, there is one element commonly found inmost Complete Streets projects, and that is the creation or enhancement of pedestrian and bicycle-related features. These design features are aimed atgetting individuals to leave behind their automo-biles and use alternate modes of transportation.

For example, multi-modal inter-sections link pedestrian serv-ices with those for bicyclingand mass transit. Once atransit user leaves the transitvehicle, s/he typically becomes a pedestrian.Therefore, it is vital that aComplete Streets proj-ect includes improveddirectional and infor-mation signage andpavement markingsalerting pedestriansto the location of

crosswalks, as well as street furniture (e.g., benches,way-faring signs), bike racks, drinking fountains,and street merchant pads.

In addition, a Complete Streets project can encour-age individuals to walk more by incorporating features that ensure their safety. This includes reducing the pavement width of arterial streets. Bynarrowing the pavement for the travel way, thespeed of the traffic is slowed, since wider streetstypically encourage motor vehicle operators todrive faster.

Tremendous BenefitsOne example of a Complete Streets project isshown below and on the previous page (beforeand after). Note the expansive pavement width,four lanes of traffic, and little or no provisions forpedestrians or bicyclists in the “before” photo. Thephoto opposite shows the project as currentlyunder design. (It’s slated for construction in 2012.)

Benefits include a reduction in the number andwidth of vehicle travel lanes, as well as better defi-nition of these lanes. Additional amenities includethe creation of bike lanes, improved accommoda-tions for pedestrians by increasing the sidewalklength, connectivity for bicycles and pedestrians,and reduced and safer crossing distances forpedestrians. Other improvements include reducingthe length of cross walks, adding median islands,making pedestrian signals more accessible andmore pedestrian friendly, and extending curbs.

Designating Roadway Space for BicyclistsTowns and cities are also designating roadwayspace for bicyclists, as this activity has becomemore popular in recent years. One of the mostpopular facilities is the bicycle lane, which is delin-eated from the adjacent motor vehicle travel laneby pavement markings or striping. Bicycle lanes areproving effective in encouraging residents and

Before (above) and after (left) Complete Streets: Anderson Memorial Bridge, Cambridge, MA.


visitors to consider bicycling,which lessens the amount ofmotor vehicles on a road-way and improves air quality.

The photos at left show “be-fore” and “after” conditions, respectively, along Massachu-setts Avenue in Arlington, MA. Inthe 1950s, there were travel

lanes and parking alongboth sides of this 66-ft-wideroadway, as well as trolleytracks running down themiddle. Since then, thetrolley tracks had been re-moved, but no provisionshad been included forother roadway users. The“after” photo shows a ded-icated bike lane—thus reclaiming some of thepavement—a reduction intravel lanes, improvementsfor pedestrian crossings,and maintenance work

for parking.

Bicycle lanes typically measure four to six feet inwidth and are located on the right edge of theroadway (though they can be designated to the left of parking spaces or right-turn lanes).

Bicyclists also are accommodated by widecurb lanes (which measure 13 to 15 ormore feet in width), which allows thelane to be shared by motor vehicles andbicycles while giving sufficient room forautomobiles to pass.

Bicycle lanes and wide curb lanes(WCL) are each beneficial in theirown way. Advocates of WCLs believe that wider lanes encour-age bicycle riders to operatemore like motor vehicles,which leads to more correctmaneuvering at intersections.

Meanwhile, studies have shown that a bicycle lane’sstripes or pavement markings result in more predictable bicyclist riding behavior, fewer erraticdriver maneuvers, and enhanced comfort levels forboth bicyclists and automobile operators. With adedicated bike lane, the cyclist is typically riding inthe middle of the lane and “dooring” (i.e., when bicycles riding adjacent to parked vehicles are involved in accidents) is less likely to occur. However,some bicycle lane opponents feel these facilitiesmake it difficult for bicyclists to handle turning maneuvers at intersections, particularly right turns.

‘Green’ BenefitsComplete Streets policies can also help a commu-nity become more “green.” For example, projectsare incorporating porous pavement into their design, which allows stormwater runoff to filterthrough to the ground more efficiently. In addition,sidewalk gardens featuring specially chosen plant-ings can lower nitrogen and phosphorus levels inthe stormwater. These gardens can also includespecially structured tree planting soils, which caninclude grates and drains that irrigate the plantings;and engineered composite soils, which store andtreat runoff.

Some Complete Streets projects also include theplanting of trees and shrubs, which can improveair quality. Leaves filter the air by removing dustand other particulates and absorb carbon dioxide.Trees and shrubs also help reduce thermal pollu-tion and urban heat island effects, which are theharmful increase of water temperatures in rivers,streams, and lakes. Stormwater runoff can get hotter as it washes across impervious surfaces.When the heated runoff enters a natural watersource, it can negatively affect fish and otherwildlife that need cold water to live and breed.

Innovative TechnologiesComplete Streets projects also include innovativetechnologies designed to make roadways safer andmore environmentally friendly. These include:

• Barcodes and radio-frequency identification tags,which provide smart phone users with access toinformation regarding nearby bike-sharing pro-grams, scooter parking, and electronic vehiclecharging stations;

• On-street cameras and sensors, which analyze

Before (top) and after (bottom) Complete Streets:Massachusetts Ave., Arlington, MA.

An example of a Complete Street (above).


real-time traffic and parking trends, and can ensure smoother traffic flow and reduced trafficcongestion;

• LED street lights, which offer longer life spans,lower energy demands, and reduced mainte-nance costs;

• Leading pedestrian intervals at traffic signals,which give the pedestrian the advance prior tothe vehicle receiving the green indication;

• Better timed traffic signals and improved or additional crossing times for pedestrians;

• Countdown pedestrian signals; and• GPS devices, which help provide more efficient

travel.

An interesting example of these technologies canbe found in Salem, MA. With the support of themayor and other local officials and interests, the cityhas developed a citywide bicycle circulation masterplan. The plan designates those shared roadwaysthat should be used as bicycle routes by imple-menting “sharrows” (i.e., a shared-lane marking ona street), as well as identifying those roads that aresuitable for bike lanes and corridors for exclusivebike paths.

In addition, the plan calls for the creation of morethan 33 miles of designated bicycle routes withinthe city, including over four miles of bikeways,more than six miles of bike lanes, and 22-plusmiles of shared bike routes. Finally, the study includes a detailed evaluation of a high-priority 4.5-mile “pilot” route, as well as construction costestimates and maintenance costs. Currently, thecity is in the process of developing the pilot route.

Streets are vital to a community’s progress andwell-being, economic development, and culturalenrichment. However, all too often they have beendesigned with just motor vehicles in mind. Theconcept of Complete Streets allows municipal planners to create roadways that better serve acommunity’s residents and visitors. And not onlyare these streets becoming friendlier to all who use them, they are becoming friendlier to the environment. em

A&WMABuyers GuideTap into the incredible network of the Air & Waste Management Association with the A&WMA Buyers Guide. Powered by MultiView, the Guide is the premier search tool for environmental professionals. Find the suppliers you need, within the network of the association you trust.

Start your search today at awma.org.

30 em april 2012 awma.org

em • yp perspective

Depending on the answers to these and manyother questions, the boiler may be subject to themajor source boiler rule, area source boiler rule, orthe rule governing commercial and industrial solid waste incinerators (CISWI), not to mention the rulesissued by states that may have more stringent limits.

The boiler and CISWI rules were finalized onMarch 21, 2011, but the U.S. Environmental Protection Agency (EPA) announced a stay of theeffective date of the rule, while it reconsidered andaccepted comments on new proposals (issued onDecember 23, 2011) to change the rules. Manysources did not take action and complete adminis-trative notification requirements in the rule becauseof the stay. Though EPA had planned to stay im-plementation of the rule until the reconsiderationwas complete, a federal court ruled on January 9,2012, that the delay was not allowed, and thus therules are considered to be in effect. In response tothe court ruling, EPA indicated in a memorandumon February 7, 2012, that it is exercising its en-forcement discretion not to enforce the provisionsof the new boiler and CISWI rules until new rulesare issued this spring.

The history of these rules is long, following webs ofrule changes by EPA, and lawsuits by industry andenvironmental groups. For environmental profes-sionals just getting into the field, untangling thishistory can be as daunting as understanding therules themselves. Knowing where we have beencan help you understand where we are going.However, getting to know the rules as they are currently woven, and learning about how they arebeing reworked, will help you avoid gettingsnagged in the web.

Pick a Fuel, Pick a RuleOf course, one of the most important factors determining whether a source is subject to theCISWI rule or the boiler rules is whether the fuel isclassified as a waste. As such, the status of a boilerhinges on the definition of “nonhazardous second-ary material”, which is also up for revisions, andgoverned under the Resource Conservation andRecovery Act (RCRA) instead of under the U.S.Clean Air Act’s (CAA) National Emission Standardsfor Hazardous Air Pollutants (NESHAPs) provisionslike the boiler rules.

If the fuel is a nonhazardous waste, the boiler issubject to CISWI. If it is a traditional fuel, or a “cleancellulosic biomass” (e.g., pelletized clean wood), theboiler is subject to either the major or area sourceboiler rule.

Boiler Rules, TodayStationary sources with the potential to emit haz-ardous air pollutants (HAPs) are subject to the CAA’sNESHAPs provisions: at least 10 tons per year (tpy)of any single HAP or 25 tpy of any combinationtriggers a major source designation; sources withemissions below these limits are considered areasources. While area sources are usually subject toGenerally Available Control Technology (GACT) requirements, sometimes they must meet the morestringent Maximum Achievable Control Technology(MACT) standards similar to the major source category, which is set by the lowest emitters or themost stringent regulations in the source categoryor subcategory. GACT is characterized by less strin-gent emissions requirements, based on industrystandard technology and work practices.

Untangling the Web: Understanding

Untangling the web of requirements for industrial, commercial, and institutional boilers can be

daunting, especially for new environmental professionals. Determining which rule governs a

particular boiler can be confusing; you must navigate strings of questions to determine which

regulations apply. What are the emissions from the boiler? How big is it? What are the total

facility emissions? What type of fuel does the boiler typically burn?

This month’s column is written by Leiran Biton, anenvironmental analyst for theNortheast States for Coordi-nated Air Use Management(NESCAUM). He applies his background in technicalanalysis, model evaluation,and policy impact assessmentto support the Northeaststates’ air quality programs.Leiran is Vice Chair of theYoung Professionals AdvisoryCouncil’s Web Committee(on Twitter @AirWasteYP)and Acting Chair of the newA&WMA YPAC BostonChapter. E-mail:[email protected].

Copyright 2012 Air & Waste Management Association

awma.org

Boilers are a particularly ubiquitous source type.Combined, the area and major source rules will affect more than 200,000 boilers nationwide. Thevast majority of these units—approximately 80%—are small, existing, oil-fired boilers, which can befound in many commercial and industrial buildings.What makes the boiler rules different from nearlyany other source category under NESHAPs provi-sions is that boilers are likely to be found in almostall types of buildings, whether they are engaged inmanufacturing, commerce, institutional, or mixed-use functions. And while a typical boiler is unlikelyto trigger the MACT requirements alone, aggregatesource emissions may, and sources and regulatorsmust be prepared to meet these permitting requirements.

Boiler Rules, TomorrowSome of the biggest proposed redesigns of theboiler rules are intended to reduce administrativerequirements for industry. EPA’s proposed changesto the rules have implications for which units arecovered; what requirements for work practices andemissions limitations will apply; and when boilerssubject to the rule must demonstrate compliance,both initially and on a recurring basis.

Subcategory exemptions are a big part of the pro-posed changes. Typical residential hot water heatersare not covered under these rules. Temporary boil-ers, electric boilers, process heaters, and electricutility steam generating units are also specificallyexempted but may be subject to other NESHAPsprovisions. Seasonal boilers, limited–use boilers,and small liquid fuel-fired boilers will see reducedtune-up and testing requirements. Area sourceboilers would be exempt from Title V permittingrequirements.

EPA also proposed to add several new subcategoriesfor emissions limits of particulate matter (PM) andcarbon monoxide (CO) under the major sourcerule, based on comments and new data incorpo-rated into the supporting EPA analysis. These newsubcategories are for different configuration or design of solid fuel-fired boilers or composition of

fuel (e.g., wet vs. dry biomass, light vs. heavy liquid).There are large variations in emissions limits for PMand CO. For example, major source emissions limits for PM in existing biomass-fueled boilersrange from 0.029 to 0.44 pounds per million Btu(lb/MMBtu) and from 0.0098 to 0.32 lb/MMBtuin new biomass-fueled boilers. EPA has also proposedseparate PM emissions limits under the major sourcerule for distillate (0.0034 and 0.0067 lb/MMBtufor new and existing sources, respectively) andresidual oil (0.013 and 0.062 lb/MMBtu for newand existing sources, respectively).

Another proposed change is the allowance of alternative monitoring to more directly measurethe pollutants addressed under the NESHAPs provisions. Key among these proposals is the meas-urement of total selected metals instead of PM forsolid fuels.

EPA is also proposing to do away with numericallimits for emissions of dioxin and furan compounds,because the detection limit of the official EPA meas-urement method is higher than the proposed risk-based emission limits. Instead, EPA offers tune-upwork practice standards. In doing so, EPA indicatesthat the official measurement method is not sen-sitive enough and therefore insufficient. New tech-niques for detecting these compounds are likelyneeded to effectively implement more robust,numerical emission limits.

Crawling the WebIn some ways, young environmental professionalsare on the same footing as those who have beenworking in the industry since the rules’ inception.These rules have changed significantly in recentyears, with the overall pattern of change being toincrease regulatory and compliance flexibility whilecontinuing to improve environmental performanceand energy efficiency. And it is our job to helpthe industry to walk the new web of rules gov-erning boilers. em

Editor’s Note: This month’s feature articles, beginning on page6, take a close look at the potential impacts of the Utility andBoiler MACT rules.

YP Perspective is a monthlycolumn organized byA&WMA’s Young ProfessionalAdvisory Council (YPAC). Ifyou have a topic you wouldlike to see young professionalsdiscuss, e-mail:[email protected].

YPAC strives to effectivelyengage YPs within the Association by developingservices and activities to meetthe needs of today’s youngprofessionals. A YP is definedby the Association as being35 years of age or younger.Each YP is encouraged toget involved with the Associ-ation, whether within theirlocal Chapter or Section orwithin the Association’s fourCouncils (Education Council,Technical Council, Sectionsand Chapters Councils, andYPAC). YPs interested in get-ting involved may contactYPAC for more informationon current volunteer andleadership opportunities.

the Implications of the Boiler Regulations


awma.org

em • it insight

by Jill Gilbert

Jill Barson Gilbert, QEP,is president of Lexicon Systems, LLC. E-mail:[email protected].

With global markets, 24/7 business, and information technology (IT) changing at light speed,

there’s a lot of change to absorb. Furthermore, many organizations undergo significant business

and technology changes when they upgrade or implement new environment, health, and

safety (EH&S) software. To make these changes work, organizations need to clearly define the

expected benefits of the change, ensure people within the organization know what to expect,

and then efficiently and effectively deliver the changes.

picture when things don’t happen as expected. Be-liefs and emotions take over. One human isolateshimself in his comfort zone and gets left behind.The other human embraces change and adapts tothe situation, noting, “If you do not change, youcan become extinct.”

Organizations should expect some resistance tochange; people’s past experiences and emotionsaffect the way that they perceive change. People

fear change. How you handle the change andprepare your people can make or break

your IT initiative.

Change ManagementChange management—not to be confused

with the U.S. Department of Labor’s Occupa-tional Safety and Health Administration

Management of Change regulations, or withthe process of managing

software scope changes—is a “people” issue, oftenoverlooked or not given

adequate attention whenundertaking an enterprise

software initiative.

Change is unsettling. In Who Moved My Cheese,1

Spencer Johnson relates a tale of mice and minus-cule humans in search of cheese in a maze as ametaphor for change. When the cheese is not inthe expected location, one mouse sniffs out the situation and gets an early picture of change, whilethe other scurries immediately into action. The humans react differently. Fear of the unknown,anger, and denial enter the

Change Happens…Embrace It!


awma.org april 2012 em 33

Simply put, change management is a structuredapproach to shifting/transitioning individuals, teams,and organizations from a current state to a desiredfuture state. It is an organizational process aimed athelping employees to accept and embrace changesin their current business environment.2

The change management process is the sequenceof steps or activities that a change managementteam or project leader follows to apply changemanagement to a project or change. Most changemanagement processes contain three phases:3

• Phase 1 – Preparing for change (preparation, assessment, and strategy development)

• Phase 2 – Managing change (detailed planningand change management implementation)

• Phase 3 – Reinforcing change (data gathering,corrective action, and recognition)

Four Facets of ChangeAccording to the Integral or Four QuadrantsModel, organizations must manage four facets ofchange, each equally important.4,5 The model asserts that individual change is important to achieveenterprise change, and that change requires fourtypes of alignment (see Figure 1).

Management experts McManus and Cacioppe

build upon the Four Quadrants Model and identifyeight elements necessary for change:6

Pressure for change

Clear, shared vision and goal

Capacity for change

Actionable steps and targets

Aligned structure and systems

Model the way

Reinforce the change

Evaluate and improve

They also identify three catalysts for cultural change:

Leadership change teamPositive mind-shift and driving valuesInvolvement and communication

Tips for Managing ChangeUnderstand Your EnvironmentDefine the business problem up front—what areyou trying to accomplish (with the new software)?Assess cultural and organizational readiness forchange. If the IT initiative spans several culturesand/or several sets of requirements, then be preparedto address these “localization” issues. Understand“as is” versus “to be” states, including both manualand automated work processes and systems.

Figure 1. Four QuadrantsModel: (a) four quadrantsof change; (b) four typesof alignment required forchange to occur.

Source: Adapted from Wilber4

and Barrett.5

(a) (b)



ChangeAhead

Involve Key StakeholdersIdentify and involve key stakeholders to help easethe change. Involve change agents, people withinthe organization that are open to change and whocan influence and mentor others. Consider whetheror not vendors and customers, as well as employees,are stakeholders.

Solicit both formal and informal input. Provide multiple exposures to the new system through participation in planning, requirements workshops,design and configuration, rollout, and so forth. Getglobal representation, including key geographiesand business units. Consider local requirementsand needs, and how the proposed system will address them.

Have a PlanDevelop a change management plan during soft-ware implementation planning. Identify changemanagement activities to occur at each stage of theproject management life cycle. Recognize thattraining is an integral part of organizational changemanagement, but not the only component.

Communicate, Communicate, CommunicateDevelop a plan to communicate how and whenchange will occur. Intersperse communicationsthroughout the project management life cycle.Avoid waiting to announce a new system by invitingend users to training the week before the new systemgoes live!

Communicate software initiative goals and objectives,and report periodically on progress. Tailor com-munications to various audiences, from end usersto executives. Communicate how the new systemwill affect stakeholders, what users should expect inthe new system, how their jobs will change, andthe benefits of the new system.

Train… and Train AgainTrain key stakeholders and change agents early,during software implementation planning. Train allsoftware users, including key stakeholders, at leastonce before the system “go live” date and providenew hire and refresher training.

Keys to an effective training program include:7

Focus on business processes, not system trans-actions

Relate new business processes to the existingenvironment

Leverage a multitude of tools for training

Train the trainer

Allocate plenty of time for implementationtraining

Reinforce training with more comprehensiveorganizational change management activities

Own and Manage the ChangeDo not become a victim of change… own it! Thiscan lead to ownership and pride in the new softwaresystem. Employ a set of global key performance indicators (KPIs) to track and report on progress.

Change happens, so make the most of it! Spendadequate effort to define the desired change, assess the differences between the existing and desired states, and develop and implement athoughtful change management plan. em

References1. Johnson, S. Who Moved My Cheese?; G.P. Putnam’s Sons, New York: 1998, 2002.2. Wikipedia, Change Management. See http://en.wikipedia.org/wiki/Change_management.3. Gunter, L. Project Management: Change Management Process, January 2, 2012; available at www.pmhut.com/project-management-

change-management-process.4. Wilber, K. A Brief History of Everything; Shambhala Publications, Inc., Boston, MA: 1996, 2000.5. Barrett, R. Building a Values-Driven Organization; Elsevier, Burlington, MA: 2006.6. McManus, B; Cacioppe, R. An Integral Approach to Project Management, December 29, 2011; available at www.pmhut.com/an-integral-

approach-to-project-management.7. Six Tips for Effective ERP Software Training; Panorama Consulting, September 15, 2009; available at http://panorama-consulting.com/six-tips-for-

effective-erp-software-training/.

Do not

become

a victim of

change…

own it!


Job Summary:Position Title: Executive Director Reports to: Board of Directors Salary: NegotiableEmployer and Location: Air & Waste Management Association – Pittsburgh, PennsylvaniaType: Full time – Leadership experience in the field of environmental management preferredRequired Education: 4 year degree, advanced degree preferred

Description:The Air & Waste Management Association (A&WMA) is an international nonprofit environmental professional organization thatprovides a neutral forum for information exchange, professional development, networking opportunities, and public education;for more information please visit www.awma.org.

A&WMA is seeking candidates for Executive Director for a three-year renewable term. The preferred candidate would be a recognized leader in the field of environmental issues who is capable of leading 6,500 global members, strengthening the Association financially, and forming partnerships with other organizations.

Responsibilities:• Develop and implement business/operational strategies.• Lead and manage staff. Create an environment that best empowers the staff to advance the interests of the Association.• Establish and enhance relationships with senior government officials, industry executives, and partnered organizations.• Implement the policies of the Association and support the Board of Directors.• Maintain and grow membership; retain the highest levels of member satisfaction.

Requirements:• Advanced degree or equivalent experience in technical, business, or legal disciplines related to environmental issues, preferred.• Demonstrated ability to motivate and lead people.• Ten years of executive management in business and service development and implementation, preferred.• Superior written and oral communication skills. Strong consensus building and negotiating skills.• Experience working with a Board of Directors, preferred.• Ability to establish and maintain effective working relationships with volunteer leadership• Demonstrated problem solver and decision maker.• Excellent multi-tasking and organizational skills.• Demonstrated financial discernment. Experience in budgeting, fiscal planning, and strategic thinking. Successful management

of finances, publishing, and conferences.• Experience with non-profit organizations, preferred.

Core Competencies• Leadership – develops clear objectives and priorities, while providing an

environment that encourages teamwork and cooperation.• Problem solving – organizes, analyzes, and develops solutions to complex

problems.• Initiative – proactively takes action to improve Association’s operations and

public image.• Communication – develops and presents ideas, strategies, plans, and

solutions to all levels of the organization.• Customer Service Orientation – gets results that demonstrate a strong

customer focus.

Executive DirectorAir & Waste Management Association

Interested candidates, who meet the requirements and competencies specified above, should submit by May 4, 2012, a cover letter, resume, and salary requirements via email to [email protected].

36 em april 2012 awma.org

em • student corner

How Should StudentsSuccessful students have one eye on the job market as they progress toward their college

graduation. They are interested and ready to participate in a variety of activities at school to

help with their job search after graduation. Today’s job market is tough, and the global economy

is going nowhere. However, the 2010–2011 job outlook report from the U.S. Bureau of Labor

Statistics indicated that the employment of environmental scientists, engineers, and specialists

is expected to increase by more than 25% over the next decade. Job growth is likely to be

strongest in private consulting firms.

This month’s column is written by Ashok Kumar,Professor and Chairman, Department of Civil Engineering, University ofToledo, Toledo, OH. E-mail:[email protected].


awma.org

New complex laws and regulations in the areas ofclean air and groundwater contamination, popula-tion growth, and public awareness of environmentaldegradation are spurring the growth in employmentin this area. The emphasis in the coming years will beon preventing future environmental problems ratherthan controlling existing ones. I tell my students thatthere is enough work for environmental profession-als for the next several decades.

The question is: How should you prepare for thejob market? Securing a job in the current economymay seem like an impossible task. However, a systematic approach will land you the job of yourdreams. Below, I have outlined some of the stepsyou can take to find a job and ease your anxieties;the list is based on the tips I have given to the stu-dents who have graduated from our program overthe past 30 years.

Step 1: Assess YourselfAs you think about your job search, you should askseveral basic questions:

What do you want to do?

What will you enjoy most while working?

What are your strengths and weaknesses?

This first step may be the most difficult. The responsewill vary from person to person. Your responses,however, will help you choose the appropriatecourse for your job search.

Step 2: Engage in Activities Outside the ClassroomYou should regularly attend colloquia, workshops,and invited lectures that are organized on campusto broaden your knowledge in your field. Youshould also indulge yourself in reading professionaljournals, business magazines (including EM), andother literature in your field. Listen in on the careerwebinars organized by A&WMA. They are generallyfree to members. Think about participating in student organizations to build your management

and people skills. Hobbies related to your profes-sion are also useful for your résumé.

Step 3: Sharpen Your Public Speaking and Presentation SkillsMany students are afraid or hesitant to speak pub-licly. As an environmental professional, you cannotavoid public speaking. The key to reducing anxietyis to prepare adequately for any presentation. Themore you prepare, the less tension you will expe-rience when delivering your presentation. Thereare many books available on public speaking andplenty of tips can be found online. I encourage stu-dents to give presentations on the courses they aretaking and volunteer themselves to give lectureson their research in their advisor’s classes. Useevery opportunity you get to speak publicly. Thiswill help sharpen your presentation skills. Do notworry about question/answer sessions. You will beable to respond to audience questions if you have prepared well for the presentation.

Step 4: Participate in Student Poster PresentationsYou should try to present student posters aboutyour research during conferences held on campusand at A&WMA meetings. This gives you exposureto prospective employers and will improve yoursoft skills for the business world. Most of our gradu-ate students participate in one or the other activities.

Step 5: Engage in NetworkingNetworking is very important and easy in the Internet age. However, you should make sure thatyou are involved in the right networking from thevantage point of your job search. General socialnetworking sites will not help much in finding ajob. Attending the conferences and workshopshosted by A&WMA is one of the best sources ofnetworking. The student program, put together byA&WMA’s Education Council, is a nice way to meetprospective employers, learn how to job search,and participate in poster sessions. You should beactive in asking questions during technical presen-tations, while meeting exhibitors in the exhibition

Student Corner is a newquarterly column writtenfor (and by) student members sponsored byA&WMA’s PublicationCommittee. Have an ideafor a topic or want to author a column? E-mail:[email protected].

Prepare for the Job Market?



area, and during social gatherings. It is also usefulto build your network with other poster presentersbecause some of them will be working soon. Joindiscussion groups and be active.

Step 6: Take Advantage of Internship OpportunitiesMany employers and government agencies provideinternship opportunities in environmental areas.Take advantage of such offerings to build yourexperience. Some campuses have summer researchopportunities for undergraduate students that arefunded by external agencies.

Step 7: Think CertificationsThe required certifications will help to position youfor opportunities in environmental areas. Engineer-In-Training (EIT) certification and the Institute of Professional Environmental Practice’s Envi-ronmental Professional Intern (EPI) credentials areuseful for those who are beginning their careerin the environmental arena.

Step 8: Prepare a Current RésuméDeveloping a current résumé is an important steptoward your job search. It is never too early to startwriting a résumé. The perfect résumé is targeted toa specific job and includes all the important key-words and phrases, so that it can pass through theinitial screening process. Many hiring companiesnow employ computers to check résumés usingautomated tests to rank the candidates. You maywant to test your résumé using computerizedscreening technologies to learn about the poten-tial results, several of these are available online. Besure to also give your résumé to several professorsand academic advisors for further comments.

Step 9: Develop a Cover LetterA cover letter is an important tool in selling yourskills to a potential employer. You should be confi-dent, positive, and focused in writing the letter. Beconcise, accurate, and polite. Differentiate yourselffrom other job seekers. The cover letter should berevised for each job application.

Step 10: Research Your FieldResearch is a critical part of the job search processand it can help you in the following areas: identifycompanies that may be hiring in your field; focusyour job search on employers whose values and

expectations meet yours; and prepare yourself fora scheduled job interview. Resources available fromthe American Academy of Environmental Engineersare useful in locating environmental companiesand the names of certified environmental profes-sionals. Be sure to check A&WMA’s online CareerCenter. You can also post your résumé and lookfor job openings via the A&WMA web site,wwww.awma.org.

Do not overlook your academic advisor, professors,thesis supervisor, college employment office, andother resources and facilities available on campus.

Step 11: Prepare for an InterviewInterviews are a very important part of your jobsearch. In recent years, employers often conductinitial interviews by phone before calling candidatesin for face-to-face interviews. The purpose is generally to gather information about soft skills,such as communication, as well as technical abili-ties. Students should spend some time preparinginformation about their research work and area ofinterest before giving a phone interview. Such interviews should be taken seriously. Also, studentsshould keep themselves up-to-date with currentnews, information, and discussions in their areas ofinterest.

Prospective employees should learn about theprospective employers and their needs. This willhelp you match your skills with the job for whichyou have applied, as well as demonstrate your seriousness about the job to the interviewer. Thinkabout the questions your prospective employersmay ask. You should know about the old materialyou put on your résumé and be prepared to discuss your past job and volunteer experiences.

You should be prepared to answer questions relatedto your weaknesses also. For example, a questionrelated to lack of experience could be explained interms of different projects you completed in yourenvironmental courses. One of my students tooksamples of key assignments from his courses thatrelated to the job for an onsite interview. Anotherstudent showed the course Web site toward the endof the interview process. The idea is to successfullycommunicate your qualifications to the employer.Prepare yourself to ask questions about the com-pany, as well as the job for which you are seeking.


Step 12: Prepare for an Academic Career Students who are looking for an academic careerwill find that task more challenging than gettinginto a graduate school. In addition to the abovesteps, you should develop a statement on yourteaching philosophy, research plan, funding sources,and instrumentation needs. A curriculum vita (CV)is more appropriate for academic positions than arésumé. Professional societies, online newsletters(e.g., www.AcademicKeys.com), the American Society of Engineering Education, and the Associ-ation of Environmental Engineering and ScienceProfessors are important sources to find potentialjobs. Academic jobs typically require presentationsin front of faculty and students. You should beready with questions during the interview in orderto learn about the working environment and expectations.

Some research areas may require you to look fora position conducting postdoctoral research withan established faculty member. This will provideyou an opportunity to build a research program,learn new techniques, and get some experience atgrant writing. It is an opportunity to become an independent researcher.

Step 13: Choose ReferencesEmployers often ask for two to three professionalreferences, unless they are familiar with you andyour work. You should think carefully when you

develop a list of references. Make sure that yourreferees know you well and talk positively and enthusiastically about you based on your courseand/or research work. It is always a good idea toshare a copy of your recent résumé with whomyou use as a reference, and tell them about receiving a potential employer’s phone call or letter of inquiry.

Step 14: Thank You LetterIt is important to send a thank you letter toprospective employers after an interview. Note thatthe job search requires a lot of patience becausemost of the companies spend quite a bit of time tofind the right candidate. Do not forget also to senda thank you note to your references after you havefound employment.

Searching for a job is a time-consuming and involved process. You must be patient; do not giveup if you are getting rejection letters or if you arenot getting responses. Continue your search with apositive attitude and you will land a job in the com-ing weeks. You should be flexible in the currenttough job market and be willing to look at oppor-tunities outside your comfort zone. Get ready toface a diverse workforce. One of my professorsonce told me: if you can fill a need, you have a job.I hope you can. em

Air Quality Measurements for Science and PolicyThe May issue focuses on air quality monitoring practices and procedures from both

research and regulatory perspectives, and will cover topics such as adequacy of current

monitoring network for properly characterizing the magnitude and spatial extent of air

pollution, monitoring pollutants that pose the highest health risk, and new methods for

3-D characterization of air quality.

Also look for…Asian Connections

Competitive Strategy

PM File

YP Perspective

awma.org

em • annual conference preview

Young Professional and Student Programs at the2012 A&WMA Annual Conference

The Young Professional and Student Programs for2012 have just the right mix of intensive technical

sessions and courses, and relaxed social and networking events—

so attendees can get all ofthe technical informationthey came for, while alsohaving a great time!

Here is a preview of this year’s Young Professional Programs:

Young Professional Mentor BreakfastTuesday, June 19This networking breakfast is designed for youngprofessionals and recent graduates to have theopportunity to network and be mentored by anenvironmental professional.

Speed NetworkingWednesday, June 20Young professionals engage in speed networkingwith students. Answer questions, provide perspectives, and help students get the insidetrack of what it’s like being a practicing environ-mental professional.

Young Professional/Student Networking ReceptionWednesday, June 20Young professionals are invited to network withother young professionals, students, and A&WMAleadership over appetizers and drinks at the

Acenar, San Antonio’s most innovative andcontemporary Mexican restaurant and bar.

Honors & Awards Ceremony LuncheonSponsored by 3M & Navistar

Thursday, June 21 A&WMA honors its young professionals with twospecial awards: the Outstanding Young Profes-sional Award and the Young Professional BestPaper Award.

The 105th Annual Conference & Exhibition is the perfect place for young professionals and

students to get the latest technical information and have their voices heard by industry leaders.

Current and future environmental professionals have the chance to network with colleagues

in the field, present and publish their work, and further their professional education.


Here is a preview of this year’s Student Programs:

Student Welcome BreakfastTuesday, June 19Students participating in the Student Poster Competition and the Environmental ChallengeInternational (ECi) are invited to meet and net-work with fellow students.

Student Poster CompetitionSponsored by CHM2Hill

Tuesday, June 19 Visit the exhibit hall to watch as students presenttheir posters to the judges during this year’s competition.

Environmental Challenge International (ECi)(Poster) Judging Tuesday, June 19 Join the ECi teams as they present their postersto the judges.

Career Panel DiscussionWednesday, June 20Listen as a panel of young professional leadersshare their career experiences.

ECi PresentationsWednesday, June 20 Watch the teams present their ECi problem solutions using the “tweak” they’ve learned since arriving at the conference.

Speed Networking Wednesday, June 20 Students are invited to engage in speed network-ing with practicing professionals in varying envi-ronmental disciplines.

Academic Career Preparation WorkshopWednesday, June 20 Students interested in pursuing jobs in academiaare invited to learn about the academic job searchprocess and have the opportunity to speak withuniversity representatives.

Student Awards Ceremony and ReceptionWednesday, June 20All attending students are invited to the StudentAwards Ceremony and Reception, which willhonor exceptional students with awards andprizes.

Young Professional/Student Networking Reception Wednesday, June 20 Students are invited to network with other students,young professionals, and A&WMA leadershipover appetizers and drinks.

Student Chapter Exchange Thursday, June 21Join A&WMA staff and your fellowstudents for the Student Chapter Exchange to network and exchangeideas about A&WMA’s Student Chapters.

Register Today

Leading Environmental Frontiers105th A&WMA Annual Conference & ExhibitionHenry B. Gonzalez Convention CenterSan Antonio, TX • June 19-22, 2012ace2012.awma.org

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AIR 295: Air Quality EngineeringFull-day courseInstructor: Mark Rood This course provides a primer about the chemical and physicalprinciples pertaining to air pollutants, aerosol mechanics, visibility,opacity, air quality regulations, methods to remove gaseous andparticulate pollutants from gas streams, air quality, meteorology,and atmospheric dispersion.

EMGM 350: Corporate Ethics (Full-day course)Instructors: Hal Taback and Ram Ramanan This course focuses on the ethical issues faced by environmentalprofessionals. The course instructors will define ethics and moralsand offer examples; discuss the “cheating culture” and suggestsolutions; and discuss the life experiences that impact our atti-tudes about dealing with others.

EMGM 351: Project Management Essentials forEnvironment, Health, and Safety ProfessionalsFull-day courseInstructor: David ElamThis course is designed to help environmental professionals betterserve their organizations and advance their careers through thedevelopment and improvement of project management skills.The course format will consist of presentations and exercises.Each participant will receive a course notebook containing acopy of presentation materials.

EMGM 352: Sustainability ReportingFull-day courseInstructor: Yogendra Chaudhry This course focuses on sustainability reporting frameworks and itsbusiness benefits, and will provide attendees with the tools nec-essary to report according to international standards.

New for 2012!

Professional Development Coursesand Workshops at the 2012A&WMA Annual Conference

Leo Stander, P.E., BCEE, NSPEStander is an environmental engineering consultant specializing in air quality strategy development, air pollution permitting, and training.He has more than 40 years experience in the air pollution field, including 22 years with the U.S. Environmental Protection Agency’s (EPA)Office of Air Quality Planning and Standards. While at EPA, he held a variety of positions involved in the development of state and local airpollution control programs, including staff training and the coordination and support of policy and regulatory development activities for StateImplementation Plans (SIPs) and the Title V permits program.

Stander is currently an environmental consultant and provides training on a variety of air quality related issues. He is a registered ProfessionalEngineer in North Carolina, Florida, and Nebraska and a Board-Certified Environmental Engineer in the American Academy of EnvironmentalEngineering. He is a Fellow Member of A&WMA and a member of the Carolinas Air Pollution Control Association, Professional Engineers of

North Carolina, and the National Society of Professional Engineers. He has authored a book, entitled Environmental Regulatory Calculations Handbook, and severalpapers on regulatory aspects of air pollution control, and employee training. He has also conducted training courses on a variety of air pollution control topics.

AIR 125: An introduction to Air Pollution Control (Full-day course)Instructor: Leo Stander This course is designed for environmental profes-sionals who have a basic scientific background andwho are beginning air pollution control-related activities. The material covered during the course willinclude sources and controls of air pollution, effectsof air pollutants, ambient and emissions monitoringprocedures, air quality dispersion modeling proce-dures, air pollutant emissions estimating techniques,and air quality management.

AIR 182: Air Permitting—The Basics(Full-day course)Instructor: Leo Stander This course explains the basic requirements involvedin securing permits for sources of air pollution anddiscusses the requirements for obtaining permits fornew or modified sources (i.e., New Source Reviewrequirements) and the subsequent operating permits.

AIR 284: Boilers, Process Heaters, and Air Quality Requirements (Full-day course)Instructor: Leo Stander This course explains the various requirements involvedin securing permits for sources of air pollution, including identifying those sources affected by permitting requirements; discussing requirementssuch as SIP, PSD, NSR, NSPS, NESHAP, MACT, andTitle V; describing the permit application process andprocedures; as well as reporting and recordkeepingrequirements.


GEN 100: General Environmental ReviewFull-day courseInstructor: James Donnelly This course provides the engineer or scientist work-ing in environmental areas an overview of the basicscience and engineering important to many envi-ronmental calculations. Specifically, it is designed tobe a thorough review of the chemistry, physics, biology, mathematics, and engineering, which are in-cluded in the Body of Knowledge for the Institute ofProfessional Environmental Practice’s (IPEP) General En-vironmental Science (Part 1) portion of the QualifiedEnvironmental Professional (QEP) exam. This coursehas been updated to reflect the recently revised IPEPBody of Knowledge for this subject area. Studentsshould bring a calculator of the type allowed by IPEP(see www.ipep.org/cred-exam.html).

GENESMP 100: Environmental, Science, Management, and Policy ReviewFull-day courseInstructor: James Donnelly This course provides the engineer or scientist work-ing in environmental areas an overview of basic con-cepts used in environmental science, managementand policy. Specifically, it is designed to be a thor-ough review of the topics which are included in theBody of Knowledge for IPEP’s Environmental, Sci-ence, Management, and Policy (Practice Area D) por-tion of the QEP exam. This course has been updated to reflect the recently revised IPEP Body ofKnowledge for this subject area. Students shouldbring a calculator of the type allowed by IPEP (seewww.ipep.org/cred-exam.html).

EMGM 310: Environmental AuditingCourse for Environment Managers andAuditorsFull-day courseInstructor: Yogendra Chaudhry This course is designed to provide a basic under-standing of environmental management and auditingskills and will include sessions on key environmentalmanagement issues and environmental auditingbased on international standards/guidelines.

AIR 298: CALPUFF Modeling SystemFull-day courseInstructor: Jesse The’This course provides an overview of the CALPUFFmodeling system and its capabilities, including manyrecent developments, such as grid nesting and newoptions for chemical transformation, includingaqueous phase and aerosol reactions.

AIR 299: AERMOD—Air Dispersion Modeling SystemFull-day courseInstructor: Jesse The’The course provides attendees with a full under-standing of the AERMOD modeling system by balancing theory with hands-on real-world case stud-ies. At the end of this course, participants should beable to understand the basics of regulatory air dis-persion modeling and use screening and refinedmodels for permit applications and risk assessment.

MNG 101: Sharpen Your PresentationSkills: A Workshop For PresentersHalf-day workshop Instructor: Julie Sharp Engineers and other professionals must be able tocommunicate their ideas clearly, concisely, and effi-ciently to a variety of audiences. The content of a talkmay be excellent; but if the speaker does not deliverit well, the audience will find listening difficult. Thisworkshop covers techniques for delivering a profes-sional presentation and encourages participants tofocus on delivery techniques in a positive andlearner-centered environment.

MNG 100: Simple, Clear, Direct WritingHalf-day workshopInstructor: Julie Sharp Participants discuss and practice organizing and editing techniques to improve their writing.This interactive, two-part workshopcondenses the basics oftechnical writing intotwo main segments:packaging information(i.e., organizing and developing content) andediting information (i.e.,practicing efficient editing).

MNG 102: Individual Resume CritiquesHalf-day workshop; Participants sign up for a 20-minute sessionInstructor: Julie Sharp Your resume is a selling tool. Produce a resume thathighlights your strengths, using strategic placement,as well as describing skills and achievements withpower verb phrases. Julie Sharp, Ph.D., communica-tion consultant, offers individual resume critiques.

Train the Trainer WorkshopFull-day workshopInstructors: Rich Watson and Pam HeckelThis workshop is intended to introduce the attendeeto the wealth of environmental education materialsavailable from A&WMA, with a focus on the Envi-ronmental Education Resource Guides (EERGs). Onegood way to get these materials into the hands of ed-ucators (especially in Grades K-12 classrooms) is tohost a teacher training workshop. The instructors willprovide an overview of available materials, discussmodels for structuring a teacher workshop, and givetips on talking to teachers. Hands-on experience witha wide variety of exercises contained in the EERGswill be included to give attendees the confidence togo out and host teacher training workshops throughlocal schools and A&WMA Sections and Chapters.This workshop is intended for both teachers andA&WMA members and is sponsored by Waste Management.

Take Advantage of These Convenient Learning Opportunities!

Conveniently scheduled to coincide with A&WMA’s 105th Annual Conference & Exhibition,these full- and half-day professional development courses and workshops will be offered onSunday, June 17, and Monday, June 18, 2012, at the Henry B. Gonzalez Convention Centerin San Antonio, TX. Don’t miss out on this opportunity to enhance your professional skills!

For more information, complete course details, instructor bios, prerequisite information, andupdates, visit the conference Web site at ace2012.awma.org.

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em • news focus

Federal appellate judges pressed states and industrygroups Feb. 29 to explain how they are harmed bya U.S. Environmental Protection Agency (EPA) rulemeant to limit the applicability of greenhouse gaspermitting to the largest facilities (Coalition for Responsible Regulation vs. EPA, D.C. Cir., No. 10-1092, oral argument 2/29/12; American ChemistryCouncil vs. EPA, D.C. Cir., No. 10-1167, oral argu-ment 2/29/12).

Judges for the U.S. Court of Appeals for the Districtof Columbia Circuit questioned whether those statesand industry groups have the standing to challengeEPA’s tailoring rule for greenhouse gas permits. Ad-ditionally, the judges repeatedly asked EPA to defendits interpretation of the U.S. Clean Air Act (CAA) andquestioned whether there were other plausible interpretations offered by petitioners in which the tailoring rule would not be necessary.

The court heard oral arguments Feb. 29 in lawsuitschallenging EPA’s tailoring rule, as well as argumentsthat applying greenhouse gases to prevention of sig-nificant deterioration permitting opens a window tochallenge the agency’s long-standing interpretationof the permitting requirements. The judges heardoral argument in challenges to EPA’s greenhouse gasendangerment finding and vehicle emissions rulesFeb. 28 (Coalition for Responsible Regulation vs. EPA,D.C. Cir., No. 09-1322, 2/28/12; Coalition for Responsible Regulation vs. EPA, D.C. Cir., No. 10-1073, 2/28/12).

Judges Question StandingThe challengers are asking the D.C. Circuit to vacateEPA’s tailoring rule because it deviates from the explicit emissions permitting thresholds in the CAA.However, Chief Judge David Sentelle said affectedindustries and state regulators would be “worse offrather than better off” if the rule was struck down.“I thought the tailoring rule and timing rule actuallyreduced burdens,” he said. “What is the harm?” Thechallengers must demonstrate that they have beenharmed by the tailoring rule to show that they havestanding to challenge its requirements.

Texas Solicitor General Jonathan Mitchell said EPA’s

greenhouse gas permitting requirements imposenew burdens on industries and state regulators.Overturning the tailoring rule, which limits the applicability of the permitting requirements to onlythe largest stationary sources, would create an unworkable situation that would force EPA to aban-don or reconsider its entire permitting regime forstationary sources. “Somewhere along the linethey’ll have to back away,” Mitchell said.

The tailoring rule limits prevention of significant deterioration and Title V greenhouse gas permit-ting to new sources that emit more than 100,000tons per year of carbon dioxide-equivalent andmodified sources that increase their emissions bymore than 75,000 tons per year (75 Fed. Regist.31,514).

CAA Section 169(1) requires stationary sourceswith emissions greater than 250 tons per year toobtain prevention of significant deterioration per-mits. Sources with emissions greater than 100 tonsper year are required to obtain Title V operatingpermits.

Without the tailoring rule, EPA contends that stateregulators would be overwhelmed by the need toissue more than 6 million greenhouse gas permits,many of them for smaller sources that have not pre-viously been subject to permitting requirements.

EPA Usurping Congressional PowerIndustry groups and some states challenged thetailoring rule because it deviates from the 100-ton-per-year and 250-ton-per-year permitting thresh-olds. They argue EPA is effectively rewriting thestatute, usurping a power reserved for Congress.Additionally, challengers said Congress never intended the act to apply to greenhouse gases because the permitting thresholds are so low theymake application of the statute impossible.

“They have arrogated to themselves an extraordi-nary power” to redefine the statutory requirementsof the [CAA] “in an ongoing way,” Peter Keisler, apartner at Sidley Austin LLP representing severalindustry groups, said.

D.C. Circuit Presses Industry to Explain


However, Judge Sentelle said Congress has nottaken any action to limit EPA’s ability to regulategreenhouse gases in the nearly five years since theU.S. Supreme Court decided Massachusetts vs.EPA, which ruled greenhouse gases are pollutantsunder the CAA (Massachusetts vs. EPA, 549 U.S.497 (2007)).

EPA defended the tailoring rule as a necessary stepas it implements its greenhouse gas permitting pro-gram. It asked the judges to evaluate the tailoringrule using three court doctrines known as “absurdresults,” “administrative necessity,” and “one stepat a time” that would allow the agency to deviatefrom the text of the CAA if implementing it as written would be impossible. “No one in this casehas said we need to do it faster,” Perry Rosen, aJustice Department attorney representing EPA, said.

‘Subject to Regulation’ DisputedHowever, the American Chemistry Council andother industry groups argued EPA would not haveneeded the tailoring rule if it adopted a differentinterpretation of the prevention of significant dete-rioration requirements of the CAA.

At issue is the agency’s interpretation of Section165(a)(4), which says that best available controltechnology determinations for prevention of sig-nificant deterioration permits are required for “eachpollutant subject to regulation under this chapter.”EPA has historically interpreted that section tomean prevention of significant deterioration permitting applies to all pollutants, not just thosesubject to national ambient air quality standards.EPA has not issued air quality standards for green-house gases. However, the industry groups arguethe statute ties the permitting requirements to theair quality standards.

Keisler said EPA could interpret the statute to require only those industrial facilities already subjectto prevention of significant deterioration permittingfor traditional permits to control their greenhousegas emissions. That would allow EPA to implementits greenhouse gas program for prevention of significant deterioration without resorting to the

tailoring rule based on “theories of last resort” suchas administrative necessity and absurd results,Keisler said. It would also significantly reduce thenumber of permits issued while capturing nearlythe same amount of stationary source emissions asEPA’s tailoring rule, he said.

If the court were to accept the industry group’s argument, EPA’s greenhouse gas standards for vehi-cles would no longer automatically trigger similarregulations for stationary emissions sources becausegreenhouse gases would not qualify as “subject toregulation” under Section 165, Judge Sentelle said.

‘Extremely Significant Consequences’That interpretation would have “extremely signifi-cant consequences” for EPA’s argument that it hadno choice but to deviate from the text of the CAAand issue the tailoring rule, Judge David Tatel said.Rosen said the industry group’s interpretation “sub-verts statutory intent.”

Sean Donahue, an attorney representing the Envi-ronmental Defense Fund and other environmentalgroups, said the industries’ interpretation would notalleviate the need to issue permits to 6 millionsources under Title V of the CAA. Additionally, thatinterpretation would preclude EPA from regulatingnot only greenhouse gases under the prevention ofsignificant deterioration program, but all pollutantsfor which there are no air quality standards, Don-ahue said. EPA has regulated other pollutants suchas hydrogen sulfide, fluorides, and hydrochloroflu-orocarbons under the prevention of significant deterioration program, states and environmentalgroups intervening on behalf of EPA said.

Issues Decided in Alabama PowerEPA’s attorneys said the industry groups lack theability to challenge the prevention of significant deterioration program because the court in AlabamaPower vs. Costle determined that the permittingprogram applies to any regulated pollutant, not justthose that are subject to air quality standards (Alabama Power vs. Costle, 636 F 2d 323, 353-54,13 ERC 1993 (D.C. Cir. 1980)).—By AndrewChilders, Bloomberg BNA em

Challengers say

Congress never

intended the

CAA to apply to

greenhouse

gases.

Harm from EPA Tailoring Rule


em • news focus

News Focus is compiled from the current edition of Environment Reporter, published by Bloomberg BNA, www.bna.com. Note: All amounts in U.S. dollars.

EPA extended by one year the deadline by whichstates and localities must begin using a new mobilesource emissions model for transportation con-formity determinations, according to a final rulepublished Feb. 27 (77 Fed. Regist. 11,394).

State and local agencies need more time to transi-tion to the MOVES2010a (Motor Vehicle EmissionSimulator) emissions modeling system, EPA said.Under the new deadline, MOVES2010a must beused for regional conformity analyses beginningMarch 2, 2013, instead of March 2, 2012.

Transportation conformity refers to a requirementin the CAA to ensure that federal highway andtransit projects are consistent with state implemen-tation plans for air quality. EPA in October 2011published a direct final rule saying it did not expectthe grace period extension to be controversial.However, in December 2011 EPA withdrew the direct final rule, saying it had received an adverse

public comment. EPA then proceeded with therulemaking process based on a proposal it also issued in October 2011.

Rule Not Changed from ProposalDespite the negative comment, the final rule beingpublished Feb. 27 in the Federal Register is notchanged from the proposed version of the rule.“This final rule is critical to helping state and localagencies during this unique transition,” EPA said inthe final rule. EPA has said there are “significanttechnical differences” between the MOVES2010amodel and the previous model, called MOBILE6.2.

The agency released MOVES2010 in March 2010and set a two-year grace period. In September 2010,EPA announced updates to the program, designatedas MOVES2010a, and retained the original grace period. State and local agencies have told EPA theyneed additional time to transition to MOVES2010a.—By Jessica Coomes, Bloomberg BNA em

Collins Submits Amendment to Highway Bill to Delay Air Toxics Standards for Boilers

Sen. Susan M. Collins (R-Maine) submitted an amendment to the highway and mass transit bill that would delay air toxics standardsfor boilers. The Senate planned to vote the week of March 5 on amendments to the $109 billion transportation bill (S. 1813), butat the time of this writing Senate leaders had not settled on a list of amendments that would be considered. As of Feb. 28, senatorshad submitted 238 amendments.

The Collins amendment is the text of S. 1392, the EPA Regulatory Relief Act, which the senator introduced in July, but which has notbeen voted on. The measure would block EPA from issuing revised air pollution standards for boilers for 15 months after enactment,and it would give industry at least five years to comply with the rules, an increase from three years allowed under the CAA.

The House in October passed companion legislation (H.R. 2250) to delay theboiler standards.

Earthjustice attorney Jim Pew criticized the proposed delay Feb. 29.

“People who live near industrial power plants pay a disproportionate cost in increased cancer risk, heart attacks, asthma and other respiratory illness,” Pewsaid in a statement. “It’s disheartening to see Senator Collins, who has other-wise been a leader on environmental issues, sponsor legislation that wouldcarve out a loophole for toxic pollution and harm the health of her own constituents.”—By Jessica Coomes, Bloomberg BNA em

Rule Allows Grace Period Extension for Mobile Source Emissions Model

Aerosol and Atmospheric Optics: Visibility and Air PollutionSeptember 24–28, 2012Grouse Mountain Lodge, Whitefish, MTAbstract Deadline: May 25

This international conference will provide a technical forum onadvances in the scientific understanding of the effects of aerosolon urban-, regional-, continental-, and global-scale haze and radiation balance. The conference will specifically address emis-sion sources, atmospheric conditions, and aerosol characteristicsassociated with haze and aerosol urban visibility; regional haze;climate forcing; innovative aerosol, haze, and radiation balancemonitoring assessments and modeling methods; and urban andregional haze and aerosol climate forcing policy, regulatory, andeconomic issues related to implementation of U.S. Environ-mental Protection Agency (EPA) standards and rules, includingthe adopted emissions controls in state and EPA permits, rules,and implementation plans for the regional haze rule and theexpected impact of the anticipated PM visibility and SO2/NOxsecondary standards.

Recent work has suggested a much greater importance forblack carbon particles in radiative forcing and so sessions onblack carbon are planned. Sessions related to the synergisticand increasing concerns of the effects of atmospheric nitrogenand carbonaceous material on haze, climate change, and nitro-gen deposition on ecosystems are also planned. Two or moreprofessional development courses, designed to provide both atechnical foundation and a timely refresher, will be offered onsite prior to the conference. There is also a photo contestplanned, as well as a mid-conference field trip to the GlacierNational Park Class I area.

Abstract Submittal:Abstracts of 300–400 words must be submitted by May 25,2012 to [email protected]. The abstract must includethe names and affiliation of each author and indicate the presenting author. Abstracts may be submitted in Word, Word-Perfect, or .pdf format. In addition to the abstract, please indicatein the submittal e-mail: (1) name, phone number, and e-mail ofcorresponding author; (2) topic area you are submitting to aslisted in the bullets below; (3) presentation preference (poster orplatform); and (4) state if the abstract solicited by a member ofthe conference committee, and if so, by who.

If submitting more than one abstract, please indicate which isyour highest preference for platform presentation, as the antic-ipated number of submissions will limit the total number of platform presentations possible.

Presentations are invited on the following topics:• Observational Studies

• Aerosol and Visibility Field Studies and Monitoring Networks• Aerosol, Optical and Radiometric Monitoring Methods• Satellite and Other Remote Sensing Applications to

Haze/Aerosol Monitoring• New and Current Field Monitoring Techniques for

Measuring Black Carbon and Aerosol Organic Material

• Characterizing Visual Air Quality• Aerosol – Optical Relationships• Human Perception of Visibility, Including Night Sky Visibility• Urban Haze Visibility - Field Measurement and Perception

Studies Relevant to the Potential Secondary PM NAAQS• Source Attribution of Aerosol and Haze• Assessment of Haze from Natural Sources• Aerosol and Visibility Modeling at Global, Regional,

and Local Scales

• Emissions and Ambient Effects• Atmospheric Nitrogen – A Bridge between Visibility,

Ecological, and Agricultural Issues• Biomass Burning, Carbonaceous Aerosol, and Short Lived

Climate Forcers Effects on Haze and Climate• Black Carbon Emissions in Developed and Developing

Countries• Direct and Indirect Effects of Aerosol on Climate Forcing

• Policy, Regulatory, and Economic Issues Associated with:• Regional Haze Rule 2013 Check-in and 2018 Planning

Milestones to Achieve the U.S. National Visibility Goal• Implementation of the Potential U.S. EPA Secondary PM

National Ambient Air Quality Standard to protect Non-Class I Area Visibility

• Effects of Changes in Energy Supply Sources on Visibility and Aerosol Climate Forcing

• Critical Loads and Atmospheric Deposition Techniques inDeveloping and Implementing Deposition-Based Air Quality Standards

Authors will be notified of paper acceptance by July 6, 2012.Draft electronic manuscripts (up to 10 pages, including all tables,figures, and other graphics) or extended abstracts (3-5 pages,including all tables, figures, and other graphics), in either Microsoft Word or Corel WordPerfect format, are due by August 3, 2012, and final papers by September 5, 2012, to beincorporated into the online proceedings. Receipt of the finalmanuscript or extended abstract is a mandatory prerequisite foreither platform or poster presentation at the conference. Authors must follow the A&WMA Style Guide to guarantee thatpapers can be reproduced accurately in the conference proceedings.

It is anticipated that selected, peer-reviewed full manuscriptssubmitted within one month after the conference will be pub-lished in a future issue of the Journal of the Air & Waste Man-agement Association. However, as described in the Journal'sManuscript Preparation Guidelines (http://secure.awma.org/journal/edpolicy.htm), submission of a manuscript implies thatthe work has not been published previously; that it is not underconsideration for publication elsewhere; that all co-authors andinstitutes where the work was conducted approve of publica-tion; and that all authors reassign copyright to the A&WMAprior to publication.

Exhibit Space:Exhibit space will be available in the break area and near theposter session area. Interested parties should contact:

A&WMA Sales+1-412-232-3444, [email protected]

About the Venue:The conference will be held at the Grouse Mountain Lodge(www.grousemountainlodge.com) in Whitefish, MT. The areahas spectacular scenery and is within minutes of the Class I visibility protected area of Glacier National Park. Opportunitiesfor outdoor activities are abundant, including hiking, mountainbiking, Glacier National Park lake cruises, fishing, and rockclimbing.

More information:Visit www.awma.org/visibility for details. em

em • professional development programs



Events sponsored and cosponsored by the Air &Waste Management Association (A&WMA) arehighlighted in bold. For moreinformation, call A&WMAMember Services at 1-800-270-3444 or visit theA&WMA Events Web site:www.awma.org/events.

To add your events to this calendar, send to: Calendar Listings, Air & Waste Manage-ment Association, One GatewayCenter, 3rd Floor, 420 FortDuquesne Blvd., Pittsburgh, PA15222-1435. Calendar listingsare published on a space-available basis and should be received by A&WMA’s editorialoffices at least three months inadvance of publication.

em • calendar of events

Listed here are the articles appearing in theApril 2012 issue of EM's sister publication, the Journal of the Air & Waste Management Association. For more information, go to www.tandfonline.com/UAWM.

APRIL 2012 • VOLUME 62

JOURNAL

Notebook PaperAssessment of exposure to airborne ultrafine particles in the urban environmentof Lisbon, Portugal

Technical PapersComparison of seasonal phenol and p-cresolemissions from ground-level area sourcesin a dairy operation in central Texas

Rapidly eliminating pathogenic microorgan-isms in large air space using spraying .OHradicals

Volatile organic compound emissions frommunicipal solid waste disposal sites: A casestudy of Mumbai, India

Determination of air quality zones in Turkey

Determination of the emissions from an aircraft auxiliary power unit during the Alternative Aviation Fuel Experiment

Development of outcome-based, multipol-lutant mobile source indicators

Comparison of on-road emissions for B-0,B-10, and B-20 in transit buses

Optimizing nutrient supply in a rotatory-switching biofilter for toluene vapor treatment

The emission patterns of volatile organiccompounds during aerobic biotreatment ofmunicipal solid waste using continuous andintermittent aeration

Effects of improved spatial and temporalmodeling of on-road vehicle emissions

Characteristics of penicillin bacterial residue

APRIL 20–222012 A&WMA Leadership Training Academy, Pittsburgh, PA

Calling All A&WMA Volunteer Leaders!Please join us for the Association's annual Leadership Training Academy. We are delightedto present a program created exclusively for our volunteers that will strengthen your lead-ership skills, give you ideas that can be implemented within your local member units com-mittees, councils, and boards, and provide you with outstanding networking opportunities.This will be your connection to exciting ideas, essential tools, and exceptional people.

The program will take place at the Renaissance Pittsburgh Hotel in Pittsburgh PA.Please contact Stephanie Glyptis at [email protected] for more information. We hopeyou will take advantage of this excellent opportunity, and look forward to seeing you!

2012MAY10–11 Understanding Today’s Clean Air Act

Permit Programs Workshop, Atlanta, GA

JUNE19–22 A&WMA’s 105th Annual

Conference & Exhibition, San Antonio, TX

AUGUST8–16 Air Quality at the Interface: Mega Cities

and Adjacent Agroecosystems, Society ofEnvironmental Toxicology and Chemistry/Pan American Advanced Studies Institute,La Plata, Argentina; www.setac.org/pasi

20–23 Mega Symposium, Baltimore, MD

SEPTEMBER24–28 Aerosol and Atmospheric Optics:

Visibility and Air Pollution, GrouseMountain Lodge, Whitefish, MT

OCTOBER3–4 Vapor Intrusion 2012, Denver, CO

22–24 Thermal Treatment Technologies/Hazardous Waste Combustors, New Orleans, LA

NOVEMBER7–9 A&WMA’s Pacific Northwest International

Section (PNWIS) 2012 Annual Confer-ence—The Crossroads of the Environmentand Economy, Portland, OR; http://oregonawma.org/OregonPNWIS.htm

CONFERENCE 105TH ANNUAL CAL

REACH OVER

8,000ENVIRONMENTALPROFESSIONALSEACH MONTH!

EM readers are industry leaders with buying power. Contact Alison Lizzi at

[email protected], or 412-904-6003, to find out how advertising

in EM can get your company the exposure it needs in 2012.

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