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How Hazardous Air Pollutants How Hazardous Air Pollutants Are Regulated In Permitting Are Regulated In Permitting City of Albuquerque City of Albuquerque Environmental Health Department Environmental Health Department Air Quality Division


  1. How Hazardous Air Pollutants How Hazardous Air Pollutants Are Regulated In Permitting Are Regulated In Permitting City of Albuquerque City of Albuquerque Environmental Health Department Environmental Health Department Air Quality Division Air Quality Division Dario Rocha Dario Rocha Permitting & Technical Analysis Supervisor Permitting & Technical Analysis Supervisor 1 1

  2. The 1990 Clean Air Act The 1990 Clean Air Act Amendments Amendments http://www.epa.gov/air/caa/caaa_overview.html www.epa.gov/air/caa/caaa_overview.html http:// 2 2

  3. Urban Air Toxics Urban Air Toxics � Bernalillo County has a MSA population over 250,000 and is � Bernalillo County has a MSA population over 250,000 and is thus included in EPA’ ’s Urban Air Toxics Strategy goals to s Urban Air Toxics Strategy goals to thus included in EPA reduce cancer incidences by 75%, and substantially reduce reduce cancer incidences by 75%, and substantially reduce public health risks especially among highly exposed public health risks especially among highly exposed population groups. Mobile sources are targeted as well. population groups. Mobile sources are targeted as well. � The Clean Air Act required EPA to identify a list of at least 30 � The Clean Air Act required EPA to identify a list of at least 30 air toxics that pose the greatest potential health threat in air toxics that pose the greatest potential health threat in urban areas and create a list of stationary source categories urban areas and create a list of stationary source categories contributing 90% of the listed air toxics contributing 90% of the listed air toxics � As a result, EPA identified a list of 33 air toxics of the 188 � As a result, EPA identified a list of 33 air toxics of the 188 toxic air pollutants and identified 70 source categories. To toxic air pollutants and identified 70 source categories. To date, EPA has created standards for 14 of the 70 sources. date, EPA has created standards for 14 of the 70 sources. 3 3

  4. Urban Air Toxics List of 33 Urban Air Toxics List of 33 4 4

  5. Source Categories Common in Source Categories Common in Bernalillo County Bernalillo County � Gas Stations � Gas Stations � Stationary Internal Combustion Engines � Stationary Internal Combustion Engines � Dry Cleaners � Dry Cleaners � Paint & Body Shops � Paint & Body Shops � Hospital Sterilizers � Hospital Sterilizers � Municipal Landfills � Municipal Landfills � Chrome Electroplating � Chrome Electroplating 5 5

  6. Title III – – Air Toxics Air Toxics Title III http://www.epa.gov/air/caa/caaa_overview.html www.epa.gov/air/caa/caaa_overview.html http:// 6 6

  7. Regulating Hazardous Air Pollutants Regulating Hazardous Air Pollutants http://www.epa.gov/Compliance/monitoring/programs/caa/neshaps.html ml http://www.epa.gov/Compliance/monitoring/programs/caa/neshaps.ht 7 7

  8. Maximum Achievable Control Maximum Achievable Control Technology – – “ “MACT MACT” ” Technology � The 1990 Clean Air Act Amendments led to the � The 1990 Clean Air Act Amendments led to the creation of standards for hazardous air pollutants that creation of standards for hazardous air pollutants that are “ “technology based technology based” ” and are not health based and are not health based are standards or ambient standards that are analyzed in standards or ambient standards that are analyzed in an air dispersion model an air dispersion model � MACT definition � MACT definition – – “ “The maximum degree of reduction The maximum degree of reduction in HAP emissions the Administrator determines is in HAP emissions the Administrator determines is achievable, considering the cost of achieving the achievable, considering the cost of achieving the reduction and any non- -air air- -quality health and quality health and reduction and any non environmental impacts and energy requirements” ” environmental impacts and energy requirements [CAA § § 112(d)(2)]. 112(d)(2)]. [CAA 8 8

  9. Maximum Achievable Control Maximum Achievable Control Technology – – “ “MACT MACT” ” Technology For New Sources: For New Sources: � The emission control achieved in practice by the best � The emission control achieved in practice by the best controlled similar source [CAA § § 112(d)(3)] 112(d)(3)] controlled similar source [CAA For Existing Sources: For Existing Sources: � The average emission limitation achieved by the best � The average emission limitation achieved by the best performing 12% of existing sources if there are 30 or performing 12% of existing sources if there are 30 or more sources / facilities [CAA § §112(d)(3)(A)], or 112(d)(3)(A)], or more sources / facilities [CAA � The average emission limitation achieved by the best � The average emission limitation achieved by the best performing 5 of the existing sources if fewer than 30 performing 5 of the existing sources if fewer than 30 sources / facilities [CAA § §112(d)(3)(B)] 112(d)(3)(B)] sources / facilities [CAA 9 9

  10. The National Emission Standards for The National Emission Standards for Hazardous Air Pollutants Hazardous Air Pollutants � The actual standards are codified under 40 CFR 61 � The actual standards are codified under 40 CFR 61– – “National Emission Standards for Hazardous Air National Emission Standards for Hazardous Air “ Pollutants” ” and 40 CFR 63 and 40 CFR 63 – – “ “National Emission National Emission Pollutants Standards for Hazardous Air Pollutants for Source Standards for Hazardous Air Pollutants for Source Categories” ” Categories � “ � “NESHAP NESHAP” ” is the acronym commonly used for these is the acronym commonly used for these standards standards � The NESHAP standards are delegated to the � The NESHAP standards are delegated to the COA/EHD/AQD and enforced locally through 20.11.64 COA/EHD/AQD and enforced locally through 20.11.64 NMAC – – Emission Standards for Hazardous Air Emission Standards for Hazardous Air NMAC Pollutants for Stationary Sources Pollutants for Stationary Sources 10 10

  11. NESHAP Source Categories NESHAP Source Categories � If a � If a “ “source category source category” ” is subject to the is subject to the NESHAP regulations under 40 CFR 61 or NESHAP regulations under 40 CFR 61 or 63, the requirements are incorporated into 63, the requirements are incorporated into the air permit issued by the AQD and the air permit issued by the AQD and enforced through 20.11.41 NMAC. enforced through 20.11.41 NMAC. 11 11

  12. NESHAP Source Categories NESHAP Source Categories Requiring Permits Requiring Permits � (examples most common in Bernalillo � (examples most common in Bernalillo County: Dry cleaners, gas stations, paint County: Dry cleaners, gas stations, paint and body shops, chrome electroplaters) and body shops, chrome electroplaters) � Cement Distribution Terminals such as � Cement Distribution Terminals such as American Cement are not listed as a American Cement are not listed as a “source category source category” ” subject to NESHAP subject to NESHAP “ requirements. requirements.

  13. NESHAP Source Categories NESHAP Source Categories � List of Source Categories subject to the � List of Source Categories subject to the NEHSAP regulations can be found at the NEHSAP regulations can be found at the following links: following links: http://www.epa.gov/ttn/atw/mactfnlalph.html www.epa.gov/ttn/atw/mactfnlalph.html http:// http://www.epa.gov/ttn/atw/area/arearules.html www.epa.gov/ttn/atw/area/arearules.html http:// 13 13

  14. Questions? Questions?

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