clean air act compliance
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Clean Air Act Overview
The Clean Air Act is a United
States federal law designed to
control air pollution on a
national level. It required the
Environmental Protection
Agency (EPA) to develop and
enforce regulations to protect
the general public from
exposure to airborne
contaminants that are known
to be hazardous to human
health.
Clean Air Act Overview (cont.)
The 1963 Act
established a basic
research program,
which was expanded in
1967. The major
amendments to the law,
requiring regulatory
controls for air pollution,
were enacted in 1970,
1977 and 1990.
Clean Air Act Overview (cont.)
The Clean Air Act is
significant in that it was the
first major environmental law
in the United States to
include a provision for citizen
suits. Numerous state and
local governments have
enacted similar legislation,
either implementing federal
programs or filling in locally
important gaps in federal
programs.
1990 Amendments
• Created extensive Specific
Controls for
• nonattainment areas
• Extensive new requirements
for vehicles and fuels
• Established the Ozone
Transport Region and
Commission
• New cap and trade Acid Rain
Program
1990 Amendments (Cont.)
• Stratospheric Ozone
Protection provisions
• Established new Title V
Operating Permit Program
• Extensive new enforcement
authorities
• Expanded authority for the
Hazardous Air Pollution
program
Acronyms• CAA – Clean Air Act
• CAP – Criteria Air Pollutants
• NAAQS – National Ambient Air Quality Standards
• HAP – Hazardous Air Pollutants
• NSR – New Source Review
• PTE – Potential to Emit
• BACT – Best Achievable Control Technology
• MACT – Maximum Achievable Control Technology
• LAER – Lowest Achievable Emission Rate
• SIP – State Implementation Plan
7 Criteria Air Pollutants• Particulate Matter (PM10, PM2.5)
• Sulfur Dioxide (SO2)
• Nitrogen Dioxide (NO2)
• Carbon Monoxide (CO)
• Ozone (O3)*
• Lead (Pb)
*Note: The pollutant ozone is not emitted
directly into the air, but is formed from
precursor emissions of nitrogen oxides
(NOx) and volatile organic compounds
(VOC) during the ozone season. Likewise
much of the PM2.5 emissions are sulfates
and nitrates that form from SOx and NOx.
Hazardous AirPollutants•Are those pollutants that are known or suspected to
cause cancer or other serious health effects, such
as reproductive effects or birth defects, or adverse
environmental effects.
•There are a total of 187 pollutants
• Some examples are: benzene, perchloroethylene,
methylene chloride, toluene, and metals such as
cadmium, mercury, chromium, and lead
compounds.
Potential to EmitMeans the maximum capacity of a facility or a
stationary source to emit any air contaminant or
pollutant under its physical and operational design.
Potential to Emit (cont.)
• Potential to emit refers to the highest amounts of
certain pollutants that your business could
release into the air (even if you have never
actually emitted the highest amount). Potential to
emit considers the design of your equipment. It
can also consider certain controls and limitations
on the operation of your business
Remember
8,760 hours
Example
Calculation• If ABC Company has a spray coating operation that uses
the following equipment and material:
• Flow rate of spray guns = 7 ounces per minute
• Average pounds per minute = 0.4375 (7 ounces/minute / 16
ounces/pound)
• Pounds per hour = 26.25 (0.4375 pounds/minute X 60
minutes/hour)
• 8760 hours = EPA maximum operation rate
• Average percent VOC of coatings = 40%
• Number of spray guns in operation = 4
Example
Calculation (cont.)• Step 1
• 26.25 lbs. of coating used per hour multiplied by 8760 hours =
229, 950 pounds of Coating
• Step 2
• 229, 950 lbs. of Coating multiplied by 40% = 91,980 lbs. of VOC
used
• Step 3
• 91,980 lbs. of VOC used multiplied by (f) 4 = 367,920 Lbs. Of VOC
• ABC Co Potential to Emit = 367, 920 lbs. Of VOC or
183.96 tons
Best Achievable Control
TechnologyMeans what air pollution control technology will be
used to control a specific pollutant to a specified
limit. When a BACT is determined, factors such as
energy consumption, total source emission,
regional environmental impact, and economic
costs are taken into account.
Maximum Achievable
Control Technology
• Is a level of control that was introduced by Title III
of the 1990 Clean Air Act Amendments.
•The purpose of these Amendments was to
expedite the development of standards that
would reduce HAP emissions at specific source
categories
Maximum Achievable
Control Technology (cont.)Some example Industries:
• Aerospace
• Chemical Preparations
• Chromium Electroplating
• Chromium Compounds
• Dry Cleaning
• Industrial, Commercial and
Institutional
Boilers and Process Heaters-Area
Sources
• Misc. Coating Applications
• Misc. Organic Chemical
Production and Processes (MON)
Major Source of Hazardous
Air Pollutant
Sources that emit 10 tons
per year of any single HAP
OR
25 tons per year of any
combination of HAP.
Source Classification Code
• The EPA uses Source
Classification Codes to
identify both mobile and
stationary sources to classify
different types of emission
activities
• SCCs are the way the U.S.
Environmental Protection
Agency categorizes sources
of air pollution.
Emission Factors• An emissions factor is a representative value that
attempts to relate the quantity of a pollutant released to
the atmosphere with an activity associated with the
release of that pollutant.
• These factors are usually expressed as the weight of
pollutant divided by a unit weight, volume, distance, or
duration of the activity emitting the pollutant (e.g.,
kilograms of particulate emitted per megagram of coal
burned).
Title V PermitsEach facility that is a major
source of air pollution, has the
potential to emit specific
pollutants above a certain
threshold, or falls into a specific
category is required by the federal
Clean Air Act (CAA) to obtain a
Title V Operating Permit, which
consolidates all air pollution
control approvals, permits and
requirements into a single
enforceable document.
Who Needs a Title V Permit?• Existing facilities with the potential to emit 50 or more tons
per year of volatile organic compounds (VOC), 50 or more
tons per year of nitrogen oxides (NOx), 10 or more tons
per year of a single Hazardous Air Pollutant (HAP), 25 or
more tons per year of combined HAPs, or 100 or more
tons per year of any other pollutant.
Title V Reports
Semi-annual Emission Report• Due by January 31st and July 30th
• State approved forms
• Typically Only need to complete first
page if in compliance
What is the CAM Rule?
40 CFR Part 64 - Compliance
Assurance Monitoring
• Implements the monitoring
design principle for a
reasonable assurance of
compliance
• Targets facilities with add-on
control devices
• Requires source owners to
design monitoring to fit site
and incorporate into permits
Who Will Be Affected the CAM Rule?
Rule applies to each pollutant-specific emissions unit (PSEU) that:
• Is located at major source subject to Title V operational permits program, and
• Is subject to emission limitation and has a control device to meet that limit (e.g., ESPs, scrubbers, fabric filters), and
• Has precontrol emissions >major source size threshold (e.g., >100 tons/year uncontrolled emissions).
Who is Exempt from CAM?
• Exemptions are by rule type,
not facility type:
• Acid rain rules,
• Post-1990 EPA rules,
• Rules with continuous
compliance determination
methods (e.g., Da facilities for
SO2).
• One exemption exception:
Municipally-owned peaking
units.
Ozone Depleting
Substances (Cont.)
• General CFC/HCFC Unit Requirements:• Report any release greater than 100 lbs in a 24 hour period
• Technicians and recovery equipment must be EPA certified
• Use only EPA certified re-claimers and disposal facilities
• Maintain service records including, Date, Type of service and amount of refrigerant added
• Units with 50 Lbs of CFC’s or more • Maintain Inventory/Register
• Report leaks in excess of EPA leak rates
• 35%/year for commercial/industrial
• 15% for comfort cooling
• 100 lbs in 24 hours
Steps For An Effective CAA
Program Consist Of…Establishing a facility-wide emission unit inventory
Determining regulatory/permit applicability – acquire needed
permits (State and EPA specific)
Establishing “ownership” for emission units – regular
communication with these stakeholders
Developing CAA operation & maintenance calendar
w/responsibilities
Steps For An Effective CAA
Program Consist Of…Implementing internal data reporting/tracking system –
utilize existing systems
Pre-Construction/Renovation review
CFC reclamation program (in-house or contractor)
Implementing a recordkeeping/external reporting system (fuel
use, sulfur content, CFCs log, efficiency tests, O&M records, source registration,
etc.)
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