CAA | Air Program Compliance
The Clean Air Act of 1970 (CAA) and subsequent amendments provide the regulatory framework for regulating air emissions from stationary and mobile sources. The CAA and its amendments established many of the regulatory programs in use today to control air emissions. The CAA of 1970 established the National Ambient Air Quality Standards (NAAQS), New Source Performance Standards (NSPS), and the National Emission Standards for Hazardous Air Pollutants (NESHAPs). The NAAQS established national standards for six criteria pollutants which are considered harmful to public health and the environment. The NSPS rule required that stringent standards be developed for specific sources of new and modified industrial facilities. The NESHAPs rule required the development of special standards for specific hazardous air pollutants not included in the NAAQS standard.
The CAA was first amended in 1977 because many areas of the country were still considered to be in “nonattainment” of the NAAQS set in the CAA. The 1977 amendments established the New Source Review (NSR) program. The NSR program required new and modified major facilities in attainment areas to obtain construction permits and install best available control technology (BACT), while new and modified major facilities in nonattainment areas were required to obtain construction permits and achieve the lowest achievable emission rate (LAER).
The CAA was last amended in 1990. Many areas of the country still had not met the NAAQS set by the CAA of 1970. The 1990 amendments strengthened the RACT and NSR requirements for major sources and included smaller sources in seriously polluted areas, strengthened the NESHAP program by establishing a list of 189 toxic pollutants to be regulated, and required the development of risk management plans (RMPs) for extremely hazardous substances.
Title V of the 1990 amendments added a stronger operating permit program. The new operating permit program required nearly all sources of significant air emissions to apply for and obtain an operating permit. The new permits included emission limitations, schedules of compliance, monitoring requirements, and the submittal of compliance reports.
ESC has established experience in providing our clients support and guidance to understand their obligations under these requirements and ensure regulatory compliance.
We look forward to assisting you.
Air Compliance Services
The following is a sampling of key project services that have been provided to our satisfied clients:
- Air Permitting – ESC assists our clients with their permitting needs, including permit applications, modifications, and renewals. Our permitting services include Title V permits, Air State Facility permits, Synthetic Minor and Natural Minor permits, and Preconstruction permits.
- Permit Compliance – Our clients depend on us to keep them in compliance with their permit requirements. ESC performs the required recordkeeping, ensures that the facility stays within their emission limits, and performs the required periodic reporting. Reporting requirements includes semi-annual deviation reports, annual compliance reports, and annual emission statements.
- Review of Compliance with Regulatory Standards – ESC will review the operations at the facility and determine whether the facility is subject to regulatory standards, including NSPS and NESHAPs. If subject, ESC will work with the facility to ensure they are in compliance.
- Emissions Monitoring – ESC assists our clients with their required emissions monitoring. Emissions monitoring includes preparation of stack test protocols, review of CEMs data, submittal of quarterly monitoring reports, and review of required control device test audits.