Issue Date: Dec. 16, 2008 Rev. 1.

EHS-GLOBAL-E-FW022

Title Air Management

Scope
This procedure outlines the requirements for managing air emission sources, including: source identification,
emissions estimates, permitting requirements, operational controls and training.

EHS-GLOBAL-E-FW014 Management of Change and Preventive Maintenance

EHS-GLOBAL-E-F022a Air Emission Source Inventory Form
EHS-GLOBAL-E-F022b Emission Estimating Tools
Associated EHS-GLOBAL-E-F022c Structured What-If Tool (SWIFT)
documents

Author Dustin Campbell Owner Global EHS Leader

Approval EHS Leadership Team Classification For internal distribution only.

Revision Issue date Summary of change

1.0 01/10/08 First issue
1.1 Dec. 16, 2008 Formatting Corrections

A PRINTED COPY OF THIS DOCUMENT IS UNCONTROLLED

No part of this document to be reproduced or disclosed to any other party without the permission of GE

EHS-Global-E-FW022 Rev: 1 Page 1 of 7

CONTENTS
1. SCOPE..........................................................................................................................................................................3
2. DEFINITIONS............................................................................................................................................................3
3. RESPONSIBILITIES.................................................................................................................................................3
4. PROCEDURE.............................................................................................................................................................4
4.1 Site Inventory and Characteristics................................................................................................................................4
4.2 Permits and Rule Requirements....................................................................................................................................5
4.3 Air Compliance Management.......................................................................................................................................6
4.4 Operational Control......................................................................................................................................................6
4.5 Ozone Depleting Substances........................................................................................................................................6
5. TRAINING..................................................................................................................................................................6
6. auditing.........................................................................................................................................................................7

EHS-Global-E-FW022 Rev: 1 Page 2 of 7

1. SCOPE
This procedure outlines the requirements for managing air emission sources, including: source identification,
emissions estimates, permitting requirements, operational controls, record keeping and training.

2. DEFINITIONS
2.1 Air Contaminant (Air Pollutant) – any air emission that is regulated by a government authority.
2.2 Air Emission – Generic term referring to a chemical or group of chemicals or particulate matter released
into the air.
2.3 Air Emission Source – includes all process units and operations that generate stack and/or fugitive air
emissions. These process units and operations may include boilers, furnaces, process heaters, incinerators,
fuel and raw material storage and handling systems, chemical processes, machining and other metal
working, welding, painting and other surface coating, degreasing and other surface cleaning, abrasive
blasting and other surface preparation, product testing and product handling and packaging. Bathroom
vents and cooking vents are not air emission sources for the purpose of the Air Element. Note that
refrigerant-containing equipment or halon systems containing > 50 lbs (23 kgs) of refrigerant should also
be identified as regulated components and included in your inventory, even though these components do
not normally have emissions to the atmosphere.
2.4 Control Device – any device or capture system that limits the discharge of any air contaminant. Examples
include filters, catalytic converters, air scrubbers, dust collectors, baghouses, incinerators, carbon
adsorbers, etc.
2.5 Emission Factor – the relationship between the amount of air contaminant produced and the amount of raw
material or equipment used, processed, or burned.
2.6 Fugitive Emissions – any air emission that does not pass through a vent or stack or is not caught by a
capture system. Fugitive emissions are often due to equipment leaks, evaporative processes and
windblown disturbances.
2.7 Permit – The term "permit" is used broadly and includes all licenses, approvals, authorizations,
registrations, consents and similar documents issued by a regulatory agency to a site to authorize an
activity. Documentation with a regulatory agency clarifying a permit term or condition should be
considered as part of the site's permit.
2.8 Point Source Emissions – any air emission that passes through a vent, stack or capture system.

3. RESPONSIBILITIES
3.1 EHS Manager / Specialist shall:
 Ensure that all new and existing air emission sources are documented and permitting requirements are met.
 Coordinate obtaining air permits from regulatory authorities.
 Implement this air management program onsite, and obtain support from the Site Manager / Project Manager
or designee as necessary.
 Assist with evaluating and scoring site conformance to the Air Environmental Framework.
 Ensure that employees are appropriately trained on the site’s air management procedures, including permit
requirements, operational controls, recordkeeping requirements and control device maintenance requirements.
3.2 Site Manager / Project Manager or designee shall:
 Ensure that all equipment or process modifications and/or installations are communicated to the EHS
Department through the Management of Change process (EHS-GLOBAL-E-FW014) to ensure the
modification or installation is reviewed for air management requirements. EHS must be involved early in the
process due to some air regulations that require permits prior to construction or modification.
 Ensure that air emission sources are not operated if permitting requirements are not met or if control devices
are not operating properly.
 Not operate air emission sources in excess of permitted or allowable operating parameters.

EHS-Global-E-FW022 Rev: 1 Page 3 of 7

3.3 Maintenance (This could be site maintenance staff or an outside vendor) shall:
 Track periodic maintenance requirements for air emission sources and control devices and perform routine and
preventive maintenance on these sources and devices as scheduled.
 Perform routing maintenance checks of process or control equipment to ensure they are operating properly to
remain in compliance with air regulatory requirements.
3.4 Employee shall:
 Not operate any air emission source if permit requirements are not met or if control devices are not operating
properly.
 Monitor control device performance and notify maintenance if service is required.
 Maintain records of operating parameters, air emission source operating time, material usage, control device
performance (manometer readings, etc.) and other parameters as required by air permits or internal monitoring
requirement.
 Perform routine checks of process or control equipment as described by this procedure.
 Report any spills, unplanned events, excessive emissions or malfunctioning of control devices or air emission
source equipment to their supervisor and/or site EHS.
4. PROCEDURE
4.1 Site Inventory and Characteristics
4.1.1 Each site must identify and document each of its air emission sources. This should include a through survey of all
plant equipment and operations that emit air contaminants.
 Air emission sources to consider include the following:
 Fuel-burning equipment:  Finishing and Chemical Processes:
 Engines  Ovens  Painting  Parkerizing
 Boilers  Furnaces  Metalizing  Powder Coat
 Generators  Process Heaters  Plating  Rubberizing

 Cleaning Processes:  Machining and assembly

 Solvent Cleaning  Caustic Cleaning  Welding  Machining
 Parts Cleaners  Abrasive blasting  Soldering  Grinding

 Refrigerant / Ozone-Depleting Substances  Other sources

 Include any sources that contain >50 lbs. of  Comfort Heating / HVAC
charge in any individual circuit  Dust Collectors
 Each air emission source should be assigned a unique emission source identification number that is consistent
with any identification number that has been assigned in a permit or registration or represented in an air permit
application.
 The exhaust vent for each point source air emission must be identified and documented in a table, list or site
map showing its location. The general area of discharge of fugitive emissions should also be described.
 The information required to be documented for each air emission source should be maintained in a report,
spreadsheet, online database, the AirLog tool or similar method. A sample spreadsheet for maintaining an
inventory of air emission sources and related information is available as the Air Emission Source Inventory
Form (EHS-Global-E-F022a).
4.1.2 For each air emission source, the air contaminants emitted must be identified and quantified sufficiently to
determine if regulatory requirements are applicable to the specific source and/or the entire site.
 The site should use appropriate emission factors and estimating methods to estimate its source-specific and
site-wide emissions.
 Sample emission estimate spreadsheets are available as Emission Estimating Tools (EHS-Global-E-F022b).

EHS-Global-E-FW022 Rev: 1 Page 4 of 7

  Emissions estimates should then be compared to applicable regulatory limits to determine if permitting,
controls or other actions are required for the source or site.
4.1.3 For each air emission source, the required emission control equipment or other emission control requirements must
be identified and documented. Air emission control requirements include the following:
 Installation of equipment (filters, baghouses, dust collectors, carbon adsorbers, afterburners)
 Implementation of practices to control emissions (specific fuel requirements such as sulfur content, operating
time limits, raw material input limits, material specifications such as VOC content of paints and thinners,
housekeeping requirements, etc.)
4.1.4 Monitoring, recordkeeping and reporting requirements for each air emission source must be identified and
documented.
 For each air emission source, the site must conduct monitoring that is required by the permit or regulatory
agency rule and document the results of this monitoring. Monitoring may include annual stack tests,
continuous emissions monitoring systems or operating parameter monitoring systems.
 The site must maintain those records required by permit or regulatory agency rule. Recordkeeping may
include keeping process data such as the quantity of raw material used, the quantity of products produced,
operating time, process parameters, monitoring data, etc.
 Each site must meet the reporting requirements established by the regulatory agency in permits and other
rules. Reporting typically involves submitting information to a regulatory agency on a periodic basis and may
include summaries of operating or process data, emissions estimates or monitoring results, notices of upsets /
malfunctions or reporting an exceedance.
 Each site should use the PowerSuite Compliance Calendar tool to track monitoring, recordkeeping and
reporting obligations relating to air emission sources.
4.2 Permits and Rule Requirements
4.2.1 Applicable emission standards, requirements and permit limits for each emission source must be identified and
documented.
 Emission standards and requirements are typically stated in air emission permits, registrations, consents, etc.
and must be identified and documented for each source at the site. If available and active for the site, the site
may use PowerSuite Permit Tracker or similar tool to document its permit requirements.
 In some cases, these requirements are included directly in environmental laws and regulations (i.e., Texas
Permits by Rule) and must also be identified, understood and documented by the site.
 If it is determined that an air emission source is exempt from emission standards, regulatory requirements
and/or permitting, the site must document the rationale for making this determination and thoroughly describe
how the air emission source meets the exemption requirements.
4.2.2 Current copies of permits, licenses, approvals, authorizations, registrations, consents and similar documents issued
by a regulatory agency and any exemption claim documentation must be maintained at the site for each air emission source.
 A permit or exemption acknowledgement from a regulatory agency is typically required prior to beginning
construction of or installing any air emission source. The site must ensure that no air emission source is
constructed or operated without the proper authorizations.
 If a site or air emission source requires a permit that has not been previously obtained, the site should notify
business EHS personnel and obtain assistance in preparing and submitting a permit application and any
necessary fees.
 Any existing permits requiring renewal should be reviewed for accuracy and submitted for renewal prior to
permit expiration. Some permitting authorities require renewals to be submitted well in advance of permit
expiration. Check local regulations to verify permit renewal timelines and other requirements.

EHS-Global-E-FW022 Rev: 1 Page 5 of 7

4.2.3 Each site must be able to demonstrate access to potentially applicable laws and regulations relating to air
emissions. Regulations are not required to be physically present at the site but must be readily available and the method of
access understood (e.g. through the internet).
4.3 Air Compliance Management
4.3.1 Each site must designate a trained individual(s) to manage air compliance programs and activities. This person
does not necessarily have to be physically located at the site so long as it is clear to both the site and the business that the
person has air compliance responsibility for the site.
4.3.2 U.S. ONLY – If the site has received a draft or final Title V permit, a Structured What-If Tool (SWIFT) analysis
must be completed (see EHS-Global-E-F022c). This tool is designed to help the site implement monitoring, recordkeeping,
reporting and other permit requirement requirements. The SWIFT is also useful for other sites that are not subject to Title
V requirements.
4.4 Operational Controls
4.4.1 Certain air emission sources may require process or control equipment in order to meet air regulatory
requirements. If operator interaction is necessary to ensure proper functioning of this equipment, written operating
procedures must be developed to document what operator actions are necessary to properly operate the equipment and to
remain in compliance with air regulatory requirements.
 Process and control equipment procedures must be updated as necessary to ensure that they represent the
equipment in place and the activities actually conducted at the site.
 Routine checks (daily, weekly, monthly or as appropriate) of process and control equipment are required to be
performed using a checklist to ensure that all important parameters needed to assure compliance are evaluated
and recorded.
 Written operating procedures or checklists must specify how to respond to process and control equipment
operating parameters which go out of range or how to respond to equipment malfunctions.
 Written procedures must identify who should be notified in the event of air emission source upsets or control
equipment malfunction that could affect air emissions or compliance. The site EHS Manager / Specialist, Site
Manager / Project Manager representative, plant manager, department supervisor and maintenance personnel
may need to be notified to ensure the upset or malfunction is addressed and corrected.
4.4.2 Written procedures may not be necessary if process or control equipment functions regularly without operator
interaction (e.g., paint booth dry filter systems and abrasive blasting dust collectors). However, periodic maintenance and
inspection checklists must be in place for this equipment to routinely check that it is operating properly (e.g., checks of
pressure differential manometers, visual inspection of filters, etc).
4.4.3 Incidents relating to air emission sources such as permit misses or air exceedances must be reported within the
site’s Measurements tool by entering an “Air Exceedance” within the Events module. Definitions of air exceedances and
permit misses are included in the following document: [Link]

4.5 Ozone Depleting Substances

4.5.1 Ozone depleting substances (ODS) such as refrigerants must be collected and recycled to prevent their release to
the atmosphere.
 A procedure must be developed to describe the actions necessary to properly recover and recycle refrigerants
from air conditioning equipment, compressed air driers, appliances, etc.
 records should be maintained that document service activities relating to recovery and recycling of ODS. The
site may use ODS Sentinel or a similar tool to track this information.
4.5.2 Processes that consume the ozone depleting substances CFC-11, CFC-12, or CFC-13 are not allowed and must be
eliminated. Refrigeration, air conditioning and fire/explosion suppression are not considered process uses.
5. TRAINING
5.1 Personnel responsible for an air emission source must be trained within the last three years (or since the last
process modification, whichever is more recent) to ensure they understand relevant air compliance requirements.

EHS-Global-E-FW022 Rev: 1 Page 6 of 7

  Training must include recordkeeping requirements, control equipment inspection and maintenance, review of
written process and control equipment procedures, and other topics necessary to ensure all air regulatory
requirements are met.
 Personnel must also be trained to respond to operating upsets, equipment malfunctions or other causes of
abnormal emissions (such as damaged paint booth filters or broken bag filters in dust collectors).
 Training requirements may be met through classroom / toolbox meetings or through the use of computer based
training modules.
 Records of training should be maintained in Training Tracker or a similar training record management
method.
5.2 Operators of process or control equipment are expected to be able to demonstrate that they know how to operate
their equipment so as to stay in compliance with air regulatory requirements, including how to respond to
upsets/malfunctions.

6. AUDITING
6.1 Each site will conduct an annual audit of the facility’s air management program by completing the Environmental
Framework Scorecard for Environmental Framework Element 1 “Air”.
6.2 Each site will complete applicable air quality Power Audits at the frequency specified by the Power Audit tool.
6.3 Site compliance with air management framework and regulatory requirements may also be audited during Cross-
Business audits or other internal audits.
6.4 Any non-conformities or other findings identified during formal audits or other inspections will be reported and
tracked to completion in the site’s Audit Tracking System.

Procedure
Title: Air Management
Reference: EHS-GLOBAL-E-FW022
Revision: 1
Application Date: Oct. 1, 2008
Expiration Date: Null date
Author: Dustin L. Campbell

EHS-Global-E-FW022 Rev: 1 Page 7 of 7