Clean Air Act Compliance Webinar

Triumvirate Environmental presents:

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Meet Your Presenter

Rick FooteIndustrial Consulting

Services Manager

History of the Regulation

Learn more about the

Clean Air Act:

America’s Landmark

Public Health Law

Survey Question?

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

Let’s Review the

Lingo!

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.

Stack

Testing and

Emission

Factors

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).

Permitting

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

Compliance Assurance

Monitoring (CAM Plans)

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

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

Tips for Continuous

Complaince

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.)

QUESTIONS?

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this presentation

• Please complete our

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of the Q&A as well as a

free CAA assessment.

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