Smoke School History
Excerpt from Online Visible Emissions Course
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ACHIEVING CLEAN AIR THROUGH COMPLIANCE
The 1980s saw cleaner air in the U.S. through the national emissions standards and regulations; most jurisdictions met air quality standards. As a result, the EPA changed emphasis from compliance enforcement to compliance maintenance. The updates to the CAA increased the scope of regulated toxins and enhanced environmental protections. By the late 1980s much of those original criteria pollutant National Ambient Air Quality Standards (NAAQS) were met.
Method 22
In 1982, Method 22 was promulgated.
Method 22 is a visible emission observation method that simply checks for the presence or absence of visible emissions. It is to regulate fugitive emissions. In a factory setting, fugitive emissions are typically caused by leaks or damage to machinery.
The Clean Air Act Amendment (CAAa) of 1990
The 1990 CAAa targeted four harmful threats to human health and the environment.
The 1990 CAAa legislation contained many titles (sections), adding over 1,000 air toxics to the list of controlled substances, and dealt with issues needing improvement in utility, industrial, and mobile source emissions.
The 1990 CAAa addressed four major threats: acid rain, urban smog, toxic air pollution, and the hole in the Earth's ozone layer.
The 1990 CAAa amendments included the establishment of permit program requirements and expanded and updated the National Ambient Air Quality Standards (NAAQs). Additionally, the legislation updated and expanded enforcement authority, including requiring emission sources to certify their compliance, and giving the EPA authority to issue administrative subpoenas.
Penalties for noncompliance became steeper. The EPA was granted authority to issue administrative penalty orders up to $200,000 and field citations up to $5,000 for lesser offenses.
Title V Requirement
Title V operating permits become mandatory as part of the 1990 CAAa.
Title V was one of seven titles (sections) of the 1990 CAAa. The law introduced an operating permit program that was based on the design of the Federal National Pollution Elimination Discharge System (NPDES) law. Title V was introduced to ensure compliance with the CAAa and increased the enforcement authority of the EPA.
Title V's permitting program required self-monitoring and reporting, where emission sources maintain continual compliance and provide notice and self-report any non-compliance.
Title V required the following:
- Emission sources must obtain an operating permit.
- States must develop and implement the permit program.
- The EPA issues permit program regulations, reviews state programs, and oversee state programs.
- The EPA develops and implements a state program if a state fails to develop its own program.
Detailed information can be found on the EPA website.