Smoke School History

Method 22 is a visible emission observation method that checks for the presence or absence of visible emissions. It regulates fugitive emissions, which in a factory setting are typically caused by leaks or damage to machinery.

The 1990 CAAa legislation contained many titles (sections), added 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 amendments included the establishment of permit program requirements and expanded and updated the National Ambient Air Quality Standards (NAAQS). Additionally, the legislation updated enforcement authority, 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 was one of seven titles (sections) of the 1990 CAAa. The law introduced an operating permit program 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 oversees 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.