See Clean Air Acts — General and Clean Air Act — Permitting.
The Clean Air Act (CAA) of 1970 identified six common air pollutants of concern, called “criteria pollutants.” The criteria pollutants list consists of ozone, carbon monoxide (CO), nitrogen oxides (NOx), sulfur oxides (SOx), particulate matter (PM10), and lead. Environmental Protection Agency (EPA) set the specific levels, or primary standards, for these pollutants at levels EPA considered low enough to protect human health, even members of sensitive populations. EPA collects and analyzes air samples to determine whether or not a geographic region has attained these standards. If the pollution in a region continues to exceed these standards for any pollutant, EPA considers the area to be in “nonattainment.” The degree to which the pollution exceeds the primary standards will determine the level of control required on emission sources within the region. Those with the greatest amounts of pollution are subject to the highest level of controls.
See Clean Air Act — General.
Major Source of Air Pollution
Some facilities and processes emit substantial amounts of air pollutants. If a source has potential to emit in excess of specified regional thresholds, from 10 to 100 tons per year, EPA considers it a “major source” under the regulations. Major sources have more substantial requirements for permitting and pollution control than other sources. Thresholds in attainment areas are typically higher than in nonattainment areas.
New Source Performance Standards (NSPSs)
Certain types of new emission sources (generators, boilers, petroleum storage tanks, etc.) must meet new source performance standards (NSPSs). 40 CFR 60 lists the NSPSs. Also, regional requirements for emissions from new sources may be more stringent than the federal requirements.
Does this apply to my campus?
If your campus has emissions sources with a potential to emit more than 10 tons of criteria pollutants per year, you may have to comply with the permitting requirements of the CAA. If you add new combustion sources, or modify existing combustion sources, aspects of permitting requirements and NSPSs will apply.
Because of the State Implementation Program model, the mechanisms for securing these reviews and permits will vary by state. See Clean Air Act — Permitting.
What do I have to do?
Determine the attainment status of your campus’ region.
Create an emissions inventory of combustion sources on campus. Perform potential to emit calculations, measure emissions, and/or estimate emissions using EPA’s AP-42 guide to determine emissions levels at those sources. Compare those emissions levels with state program levels. Criteria pollution emissions sources might require control technology and/or permits. See Clean Air Act — Permitting.
Review Clean Air Act — Permitting if your campus plans to construct or perform modifications to any major emission sources. Design new sources or upgrades to existing sources to meet the NSPSs. Become familiar with state permitting requirements.