Corporate Compliance: Air
Aires realizes how difficult and confusing the Clean Air Act regulations can be to a facility. We provide a number of services that make obtaining a permit or operating under a permit a lot less confusing and easier to understand. Aires provides services to a variety of facilities in all 50 States and beyond.
Whether it is setting up a facility’s record keeping system to filling out the paperwork for a Title V operating permit, our Engineers work with you to understand your facility’s process to determine the type of permit required and ensure you are in compliance with applicable regulations.
Air quality addresses compliance requirements associated with air pollution emissions at industrial facilities. The Clean Air Act (CAA) is the federal enabling legislation that governs air pollution. It was first enacted in 1955 and later amended in 1963, 1965, 1970, 1977, and 1990. The 1970 amendments significantly broadened the scope of the Act, forming the basis for federal and state air pollution control regulations.
The 1990 amendments significantly expanded the scope of the Act. It produced new requirements pertaining to: non-attainment; hazardous air pollutants (HAPs); accidental releases of extremely hazardous substances (EHS); New Source Performance Standards (NSPS); stratospheric ozone-depleting chemicals (ODCs); and permitting.
Ambient Air Quality and Non-attainment Issues
As a basis for controlling air quality, the EPA has set primary and secondary National Ambient Air Quality Standards (NAAQS). Primary standards are intended to protect the health of the population; secondary standards are meant to protect the public welfare (for example, vegetation or livestock). NAAQS have been established for six pollutants, known as “criteria pollutants.” They are sulfur dioxide (SO2), particulate matter10 microns or less in diameter (PM10), carbon monoxide (CO), ozone, nitrogen oxides (NOX), and lead. The EPA designates areas as either attainment (in compliance with an NAAQS) or non-attainment (out of compliance with an NAAQS). An area may be designated attainment for some pollutants and non-attainment for others, or may be attainment for a secondary standard but not for the corresponding primary standard.
Hazardous Air Pollutants (HAPs)
HAPs are substances that may cause health and environmental effects at low concentrations but that are not regulated as criteria pollutants (though some pollutants may be regulated as both). The CAA now lists 189 HAPs; Click here to see the list of HAPs.
A major source for HAP emissions is defined as any stationary source, or a group of stationary sources located within a contiguous area under common control, that emits or has the potential to emit at least 10 tons per year (TPY) of any single HAP or 25 TPY of a combination of HAPs. EPA has the authority to establish lower emissions thresholds on the basis of potency, persistence of the HAP, potential for bioaccumulation, and other factors.
Accidental Release of Extremely Hazardous Substances (EHSs)
The 1990 CAA Amendments established several major accidental release prevention initiatives that require EPA to do the following:
- Develop a list of EHSs and establish thresholds to indicate whether a facility is regulated under the risk management program; click here to see the list of EHS;
- Establish regulations and appropriate guidance, including risk management plan (RMP) requirements, for regulated facilities;
- Create an independent Chemical Safety and Hazard Investigation Board; and
- Impose legal obligations requiring facilities to operate safely.
The EPA promulgated the list of EHSs. EHSs are defined as compounds that, if accidentally released, are known to cause death, injury, or serious adverse effects to human health or the environment. Owners/operators of a stationary major source handling any of the EHSs over a specified threshold amount must comply with the EPA’s accidental release provisions, including the development of an RMP. Threshold quantities for toxics range from 100 to 10,000 lbs; for all listed flammables, the threshold quantity is 10,000 lbs.
New Source Performance Standards (NSPS)
NSPS are federally established standards for emissions, operations, and testing that are applicable to new stationary sources constructed, reconstructed, or modified after the NSPS were proposed. There are many specific industrial facilities and operations for which NSPS have been developed. Administration and enforcement of NSPS have been delegated to many states; the current delegation status is indicated in the regulations at 40 CFR 60.
Stratospheric Ozone-Depleting Chemicals (ODCs)
The 1990 CAA Amendments deal with reducing the emissions of stratospheric ODCs for the first time. CAA requires that the EPA develop regulations mandating a phase out in the production of two “classes” of ODCs. Class I controlled substances include certain materials that are common to many industrial operations, including methyl chloroform, carbon tetrachloride, chlorofluorocarbons (CFCs), and halons. Class II controlled substances include hydrochlorofluorocarbons (HCFCs) 22, 141b, and 141c.
Registration of Smaller Sources (ROSS)
As required by Public Act 097-0095, the Illinois Environmental Protection Agency has created a new ROSS Program that is believed to apply to more than 3,000 permitted sources which combined, produce less than 1% of the air pollution in the State of Illinois. The program is intended to simplify air regulatory requirements by requiring sources with low emissions to register with the Agency rather than acquiring an air permit.
Compliance Reviews (Audits)
Aires has assisted our loyal customers with comprehensive environmental reviews (prior to, or as part of a corporate internal compliance review).
A cost effective alternative is our proprietary environmental Desk Review. INEXPENSIVE and FAST.