`Strategy for Complying with Air Pollution Control Regulations in the Chemical Industry,` published in Environmental Protection, October 2001


Courtesy of Trinity Consultants

The Clean Air Act (CAA) was originally passed by the United States Congress in 1970 and subsequently revised in 1977 for the purpose of protecting human health and the environment.

In 1990, then-President George Bush signed the Clean Air Act Amendments. The far-reaching impacts of the 1990 amendments added significantly to the regulatory challenges already faced by the chemical industry. The most striking implication of the 1990 CAAA may be the increased emphasis on enforcement issues and penalties for noncompliance. In addition, the financial impact of this legislation to the chemical industry is significant.

Now that more than a decade has passed since the milestone Clean Air Act Amendments, it seems appropriate for the chemical industry to step back and review the amendments' impact. In order to achieve and manage compliance with the 1990 CAAA, chemical facilities must first understand the provisions that have significant ramifications for the industry. A summary of these components follows.

Title I - Provisions establishing the National Ambient Air Quality Standards (NAAQS) and nonattainment status

An important provision of the original CAA was Title I, which required EPA to establish acceptable levels for six criteria pollutants: ozone, carbon monoxide (CO), particulate matter, sulfur dioxide, nitrogen dioxide, and lead. The term, 'criteria pollutants' derives from the requirement that EPA must describe the characteristics and potential health and welfare effects of these pollutants. It is on the basis of the criteria that standards are set or revised. To support attainment of these acceptable levels, states with areas classified as nonattainment are required to implement a State Implementation Plan (SIP). The SIP is designed to bring the facility into attainment with the NAAQS by the statutory deadline. These SIPs usually detail the control technologies used to reach attainment.

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