Emission Standards for Particulates

Promulgation of standards of performance under Section 111 and national emission standards for hazardous pollutants under Section 112 of the Clean Air Act is the responsibility of the Emission Standards and Engineering Division of EPA. The problems encountered and the bases used are examined.     

Data Analysis Procedures for the Ozone NAAQS Statistical Format

The Clear Air Act of 1970 established the authority to control hazardous air pollutants. Section 112 of the legislation requires the Administrator to publish, and from time to time revise, a list of hazardous air pollutants for which he intends to establish emission standards, and to establish emission standards for those pollutants. These national emission standards for hazardous air pollutants are commonly referred to as “NESHAP” standards. All of the NESHAP that have been promulgated as of April 1984 are summarized in the table which accompanies this article. Two types of references are included in the table. The first reference identifies the issue of the Federal Register in which the NESHAP is explained in detail. The second reference identifies the background information document (BID) which contains the technical and economic information developed to support the NESHAP.     

Overview of proposed air emission standards and guidelines for municipal waste combustors

The EPA proposed regulations for municipal waste combustors (MWCs) on December 20, 1989. The regulations include (1) performance standards under Section 111(b) of the Clean Air Act (CAA) for new, modified, or reconstructed MWCs and (2) draft emission guidelines and compliance schedules for the states to use to develop control requirements from existing MWCs under Section 111(d). This paper will outline the proposed air emission standards and guidelines, as well as the basis for the prescribed emission limits. The schedule for the remainder of the regulations development will also be discussed.     

Overview of Proposed Air Emission Standards and Guidelines for Municipal Waste Combustors

The EPA proposed regulations for municipal waste combustors (MWCs) on December 20, 1989. The regulations include (1) performance standards under Section lll(b) of the Clean Air Act (CAA) for new, modified, or reconstructed MWCs and (2) draft emission guidelines and compliance schedules for the states to use to develop control requirements from existing MWCs under Section 111(d).

This paper will outline the proposed air emission standards and guidelines, as well as the basis for the prescribed emission limits. The schedule for the remainder of the regulations development will also be discussed.     

A Regulatory Analysis

The information presented in this paper is directed to those individuals interested in future air quality control programs aimed at areas that are attaining one or more air quality ambient standards. Section 116 of the Clean Air Act, as amended, requires the Environmental Protection Agency to promulgate regulations for the prevention of significant deterioration (PSD) of air quality in order to protect the nation's clean air resources from hydrocarbons, carbon monoxide, ozone, nitrogen oxides, and lead (Set II pollutants). This program will affect industry siting in many areas of the country, particularly in the rural, undeveloped areas. Among the many alternatives currently being considered by EPA to meet the PSD Set II goals are emission management systems, marketable emission permits, air quality increments, emission fees, and control of transportation related sources. The final regulation may be a combination of several options or may present several alternatives from which a State would choose its specific program.     

EPA’s Clean Air Act Operating Permit Rules

Title V of the Clean Air Act requires tens of thousands of air pollution sources to obtain an operating permit incorporating all applicable requirements under the Act. EPA recently promulgated its controversial Title V regulations, which establish the minimum elements for state permit programs.

The new permit system is among the most important changes made by the 1990 Clean Air Act Amendments, and will significantly alter the way companies comply with air pollution requirements. Previously, the Act only required certain sources to obtain a new source review permit before constructing or modifying the facility (although many states established operating permit systems on their own). Now, all states must adopt operating permit programs consistent with the minimum federal requirements, and submit them to EPA by November 1993. Even though EPA has established minimum requirements, these programs are likely to vary widely from state to state.     

Impact of three interactive Texas state regulatory programs to decrease ambient air toxic levels

The Federal Clean Air Act (FCAA) framework envisions a federal-state partnership whereby the development of regulations may be at the federal level or state level with federal oversight. The U.S. Environmental Protection Agency (EPA) establishes National Ambient Air Quality Standards to describe “safe” ambient levels of criteria pollutants. For air toxics, the EPA establishes control technology standards for the 187 listed hazardous air pollutants (HAPs) but does not establish ambient standards for HAPs or other air toxics. Thus, states must ensure that ambient concentrations are not at harmful levels. The Texas Clean Air Act authorizes the Texas Commission on Environmental Quality (TCEQ), the Texas state environmental agency, to control air pollution and protect public health and welfare. The TCEQ employs three interactive programs to ensure that concentrations of air toxics do not exceed levels of potential health concern (LOCs): air permitting, ambient air monitoring, and the Air Pollutant Watch List (APWL). Comprehensive air permit reviews involve the application of best available control technology for new and modified equipment and ensure that permits protect public health and welfare. Protectiveness may be demonstrated by a number of means, including a demonstration that the predicted ground-level concentrations for the permitted emissions, evaluated on a case-by-case and chemical-by-chemical basis, do not cause or contribute to a LOC. The TCEQ's ambient air monitoring program is extensive and provides data to help assess the potential for adverse effects from all operational equipment in an area. If air toxics are persistently monitored at a LOC, an APWL area is established. The purpose of the APWL is to reduce ambient air toxic concentrations below LOCs by focusing TCEQ resources and heightening awareness. This paper will discuss examples of decreases in air toxic levels in Houston and Corpus Christi, Texas, resulting from the interactive nature of these programs.

Implications: Texas recognized through the collection of ambient monitoring data that additional measures beyond federal regulations must be taken to ensure that public health is protected. Texas integrates comprehensive air permitting, extensive ambient air monitoring, and the Air Pollutant Watch List (APWL) to protect the public from hazardous air toxics. Texas issues air permits that are protective of public health and also assesses ambient air to verify that concentrations remain below levels of concern in heavily industrialized areas. Texas developed the APWL to improve air quality in those areas where monitoring indicates a potential concern. This paper illustrates how Texas engaged its three interactive programs to successfully address elevated air toxic levels in Houston and Corpus Christi.     

A Fast Gas Chromatographic Method for Measuring C2-C6 Alkanes and Alkenes in Air

The Environmental Protection Agency is responsible for establishing, reviewing, and revising standards of performance for new stationary sources of air pollution. Since this federal program was authorized in 1970, standards of performance (commonly referred to as new source performance standards or NSPS) have been developed for 34 categories of stationary sources. These regulations have focused primarily on large new sources of particulate matter, NO _x , and SO₂ emissions. Recently, work has begun on NSPS for a number of source categories that emit volatile organic compounds. Environmental professionals in these industries and in many regulatory agencies have little direct experience with the NSPS program and are unaware of the detailed engineering, cost, and economic information available with each proposed rulemaking. This article, therefore, reviews the purposes, procedures, and benefits of the NSPS program. A summary of the NSPS that have been promulgated through February 1983 are presented in tabular form.     

Research and Evaluation of Organic Hazardous Air Pollutant Source Emission Test Methods

Abstract

Title III of the Clean Air Act Amendments of 1990 has increased the need for well defined and tested stationary source emission sampling and analysis methods. The Methods Branch of the Air Measurements Research Division of U.S. EPA's Office of Research and Development is responsible for a major methods development and evaluation program intended to help fill that need. This paper summarizes recent developments from several of the component projects of that program. Primary emphasis is placed on status and references for methods for organic hazardous air pollutants, such as phosgene, methanol, chloroform, acetonitrile, isocyanates, aldehydes, halogenated organics, non-halogenated organics, and volatile organic material     

The New Clean Air Act Operating Permit Program: EPA’s Proposed Regulations

The 1990 Clean Air Act Amendments added a new Title V to the Act which establishes an operating permit program for numerous sources of air pollution. Certain sources are currently required to obtain a construction or “new source review” permit; the 1990 Amendments will require many more sources to apply for a permit which will give them permission to operate. CAA Title V was modeled on the National Pollutant Discharge Elimination System (NPDES) permit provisions of the Clean Water Act, but there are important differences between the two statutes.

Although many states already have their own operating permit programs, by late 1993 every state must establish a program that meets the requirements of Title V and EPA’s implementing regulations. EPA recently proposed these regulations, and by the statutory deadline of November 15, 1991 hopes to issue final regulations establishing the minimum elements of state operating permit programs. These regulations will significantly affect implementation of air pollution measures for years to come because a Title V operating permit will have to assure compliance with all applicable CAA requirements. In addition, permitted sources will be required to pay fees to cover the costs of the permit program.     

Emission Inventory Case Studies—Policy Aspects

The Clean Air Act (and proposed Clean Air Act Amendments in H.R. 5252) are addressed relative to quantification of emission data. Six case studies performed for the National Commission on Air Quality (NCAQ) are reviewed. The models used to quantify the amount of emissions needed to meet air quality standards for O₃, particulates, and SO₂ are reviewed for each case study city. Technical and resource limitations in meeting the Act’s emission inventory requirements for nonattainment plans.and PSD permitting are outlined.     

Field Dynamic Calibration of SO2 Recording Instruments

Recent air pollution legislation, introduced as a Clean Air Act into New South Wales, the most populous and most heavily industrialized Australian State relies mainly upon the establishment of maximum limits of emission of air impurities. Regulations made under the Act set out the first of a series of such limits which cover the more commonly encountered pollutants. Other limits will be included later as knowledge is accumulated but, in the meantime, where standards have not been fixed the "best practicable means" of controlling air pollution must be used. To facilitate administration and to provide financial support for scientific and engineering services in the form of the Air Pollution Control Board, industries of significant air pollution potential have been designated as scheduled premises and pay annual license fees. Further technical support for the legislation is provided by an Air Pollution Advisory Committee.     

Overview of the U.S. Environmental Protection Agency's Hazardous Air Pollutant Early Reduction Program.

Under provision of the Clean Air Act Amendments of 1990 Title III, the EPA has proposed a regulation (Early Reduction Program) to allow a six-year compliance extension from Maximum Achievable Control Technology (MACT) standards for sources that voluntarily reduce emissions of Hazardous Air Pollutants (HAPs) by 90 percent or more (95 percent or more for particulates) from a base year of 1987 or later. The emission reduction must be made before the applicable MACT standard is proposed for the source category or be subject to an enforceable commitment to achieve the reduction by January 1, 1994 for sources subject to MACT standards prior to 1994. The primary purpose of this program is to encourage reduction of HAPs emissions sooner than otherwise required. Industry would be allowed additional time in evaluating emission reduction options and developing more cost-effective compliance strategies, although, under strict guidelines to ensure actual, significant and verifiable emission reductions occur.     

The OTC Challenge: Adding VOC Controls in the Northeast

The 1990 Clean Air Act Amendments create an ozone transport region made up of the northeastern and mid-Atlantic states. These new provisions call for VOC and NOx controls even in clean areas of the region in order to reduce ozone transport to downwind areas. The stationary and mobile source requirements will subject many air pollution sources to controls for the first time.

The provisions also create an Ozone Transport Commission, which can recommend that additional control measures be adopted in all or part of the region. So far, the commission has focused primarily on region-wide mobile source controls, such as California low emission vehicle standards and reformulated gasoline. But lately it has been paying increasing attention to stationary source measures, including NOx controls.     

“The Clean Air Act — A Time for Evaluation”

The Third Government Affairs Seminar sponsored by the Air Pollution Control Association was held in Washington, D. C. on April 16-17, 1975. The APCA South Atlantic Section was host for this very successful meeting. The General Chairman of the Seminar Committee was John V. Brink and the Program Chairman was Richard D. Grundy.

The seminar this year was conducted in three sessions. The first session, entitled “The Clean Air Act: State vs Federal Roles,” considered a topic that is receiving increasing emphasis as the national air pollution control program matures. This discussion was chaired by M. Barry Meyer, Chief Counsel and Chief Clerk, Senate Committee on Public Works.

The second session was “Land Use Planning Aspects of the Clean Air Act—Federal, State and Regional Roles.” Mrs. Mary Jane Due, Chairman of the Public Land and Land Use Committee, Natural Resources Section, American Bar Association, served as Moderator of this discussion of indirect source regulations, no significant deterioration, air quality maintenance—concepts that rely heavily on comprehensive land use planning.

“Clean Air Priorities—The Need for Flexibility,” was the title of the third session which was chaired by Austin H. Phelps, Manager Corporate Air Pollution Control, Procter and Gamble Company and President of APCA. The panelists considered the question of how appropriate the standard setting mechanisms of the Clean Air Act are for the resolution of present and future problems.

In this report condensed versions of the prepared statements of the participants are presented. A more extensive summary of the Proceedings, which includes questions and answers, is available from APCA headquarters. The remarks of John R. Quarles, EPA Deputy Administrator, who was the luncheon speaker, were summarized in the June APCA Journal(p. 642).     

National estimates of outdoor air toxics concentrations

The Clean Air Act identifies 189 hazardous air pollutants (HAPs), or "air toxics," associated with a wide range of adverse human health effects. The U.S. Environmental Protection Agency has conducted a modeling study with the Assessment System for Population Exposure Nationwide (ASPEN) to gain a greater understanding of the spatial distribution of concentrations of these HAPs resulting from contributions of multiple emission sources. The study estimates year 1990 long-term outdoor concentrations of 148 air toxics for each census tract in the continental United States, utilizing a Gaussian air dispersion modeling approach. Ratios of median national modeled concentrations to estimated emissions indicate that emission totals without consideration of emission source type can be a misleading indicator of air quality. The results also indicate priorities for improvements in modeling methodology and emissions identification. Model performance evaluation suggests a tendency for underprediction of observed concentrations, which is likely due, at least in part, to a number of limitations of the Gaussian modeling formulation. Emissions estimates for HAPs have a high degree of uncertainty and contribute to discrepancies between modeled and monitored concentration estimates. The model's ranking of concentrations among monitoring sites is reasonably good for most of the gaseous HAPs evaluated, with ranking accuracy ranging from 66 to 100%.     

The Law of Federal Air Pollution Control

The Clean Air Act, while recognizing the primary responsibility of states and local governments for the prevention and control of air pollution, provides authority for federal initiative and action to prevent and to abate air pollution which “endangers the health or welfare of any persons.” The applicable statutory procedures and the scope of federal authority are analyzed and discussed.     

Mercury Measurement and Its Control: What We Know,Have Learned,and Need to Further Investigate

ABSTRACT

Based on the available evidence of health effects, the U.S. Environmental Protection Agency (EPA) has been evaluating the need to regulate mercury releases to the environment. In response to the congressional mandates in The 1990 Clean Air Act Amendments (CAAA), the EPA has issued the Mercury Study Report and the Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units Report. In spite of the enormous effort represented by these reports, as well as the efforts of both the U.S. Department of Energy (DOE) and the Electric Power Research Institute (EPRI), in conducting the field measurement programs that form the basis for these reports, a definitive answer on the need for mercury regulation has not been found. However, the EPA, as well as other regulatory agencies and health researchers, have suggested a "plausible link" between anthropogenic sources emitting mercury and the methylation, bioaccumulation in the food chain, and adverse health effects in humans and wildlife.     

Sources of variability in ambient air toxics monitoring data

Under the Clean Air Act Amendments, the United States Environmental Protection Agency is required to regulate emissions of 188 hazardous air pollutants. The EPA, Office of Air Quality Planning and Standards is currently conducting a National-scale Air Toxics Assessment with a goal to identify air toxics which are of greatest concern, in terms of contribution to population inhalation risk. The results will be used to set priorities for the collection of additional air toxics emissions and monitoring data. Expanded ambient air toxics monitoring will take the form of a national air toxics monitoring network. With all monitoring data, however, comes uncertainty in the form of environmental variability (spatial and temporal) and monitoring error (sample collection and laboratory analysis). With this in mind, existing data from the Urban Air Toxics Monitoring Program (UATMP) were analyzed to obtain a general understanding of these sources of variability and then provide recommendations for managing the data uncertainties of a national network. The results indicate that environmental variability, in particular temporal, comprises most of the overall variability observed in the UATMP data. However, at lower ambient levels (on the order of 0.1–0.5 ppbv or lower) environmental variability tends to dissipate and monitoring error takes over, most notably analytical error. Overall, the results suggest that common techniques in ambient air toxics monitoring for carbonyls and volatile organic compounds may satisfy many of the primary objectives of a national air toxics monitoring network.     

The MACT for petroleum refinery FCCs is a fraud!

This paper is a continuation of the author's research on the MACT regulation for abating pollution from Petroleum Refinery FCCs in the US. This paper highlights the flaws in the recently promulgated MACT for NSPS and non-NSPS FCC units. It details the inadequacies and the potential for perversity in the New Source Performance Standards (NSPS) that are an integral part of the FCC MACT. It elaborates upon the potential for multi-media risk-exacerbations under the NSPS resulting from changes in feedstock quality, 'unit conversion', advances in cracking technology (that favour inferior crudes and feedstock), lack of NSPS standards for NO_x emissions, inter-unit transfer of contaminants/pollutants within a refinery, and the blind eye turned by RCRA to the disposal of spent FCC catalyst waste to landfills. The paper also questions EPA's motives as regards sub-categorisation of FCCs and SBREFA concessions. This paper proposes four standards that remedy these deficiencies. The first standard controls heavy metals, PM, and SO_x (along with SO₂), while the second proposes an integrated percentile control standard for CO (VOC) and NO_x emissions. The paper also proposes a percentile standard for opacity and a spent catalyst tax to control environmental risk posed by disposal of spent FCC catalyst waste to landfills. It explains the calibration of the proposed standards using a novel strategy to bridge the regulatory gap between NSPS, MACT and Residual Risk standards and demonstrates how the calibrated standards apply to FCCs processing feedstock of different qualities. The paper concludes by urging the US EPA to rescind the NSPS and the MACT for FCCs and re-promulgate an integrated set of standards for criteria and toxic pollutants along the lines proposed in this paper.