In October, the EPA issued the final rule text for an amendment to the Clean Air Act’s (CAA) National Emission Standards for Hazardous Air Pollutants (NESHAP standards). The amended rule allows major sources of hazardous air pollutants (HAPs) to reclassify as “area sources.” Permitting for air emissions requires consideration of not only the amount of emissions currently generated by operations, but also the amount thatcouldbe generated. A major source emits or has the potential to emit 10 tons per year or more of a single HAP or 25 tons per year or more of combined HAPs.
Under EPA’s old policy, once a source was a major HAP source under a NESHAP standard and the compliance date for that standard had passed, the source had to remain a major source under that standard even if it decreased its emission, installed pollution control equipment, accepted permit limits, or made other changes to decrease HAP emissions. This policy was known as the “once-in, always-in” policy. This policy was withdrawn in early 2018, and replaced with a guidance memorandum now codified by the final rule.
Two main implications of this rule change to sources affected by the previous once-in, always-in policy are:
- Sources that are no longer major sources of HAPs will no longer be subject to major source NESHAP standards and instead be subject to area source NESHAP standards or in some cases, no NESHAP standards at all. Major source NESHAP standards in most cases require more rigorous monitoring, recordkeeping, reporting, and control requirements than area source standards.
- Under the CAA major sources of HAPs are required to obtain federal “Title V”, also known as “Part 70”, operating permits. Sources that hold Part 70 operating permits solely because they are major sources of HAPs are no longer required to hold this type of permit and may be eligible for less stringent or more streamlined state permitting options (or potentially no permit at all).
这条规则可以缓解设施的监管负担，以便将其放置在主要源门槛以下的排放量。潜在排放的主要来源，其潜在的排放量大于他们的实际排放是利用这一变化的好候选人，因为它们可能能够使更简单的变化和/或接受许可限制成为区域来源，而不会影响他们通常开展业务的方式。例如，执行涂层操作（例如喷涂，印刷等）的来源通常具有远远大于其实际排放的潜在排放。由于颁布了许多迁移到水性涂料和溶剂的许多设施，因此许多这些来源的许多来源已经显着降低了他们的HAP排放量。
This rule change may also encourage major sources of HAPs to evaluate current operations and pursue changes or technological efficiencies that would reduce their HAP emissions.
If you are a major source that is able to take advantage of reclassification under this rule change, be mindful of the compliance dates, notification, and recordkeeping requirements. Because each state’s air permitting rules are different, consult with your state’s permitting authority on what steps you need to take if you are intending to reclassify as an area source. To read the final rule, clickhere。有关更多信息允许选择，请阅读我们的博客，“允许小型空气排放来源：了解您的选择”。电竞app竞猜
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