Clean Air Act Discussion: Rules, Measurement, Controls, and Legal and Medical Issues, 1994 Nonwovens Conference Proceedings

Jim Kennedy

The Clean Air Act and its recent amendments will significantly impact how business if conducted in the 1990s. Because of the impact of the Clean Air Act Amendments (CAAA), a fundamental understanding of the Clean Air Act is essential for effective business decisions. The most significant amendments affecting manufacturers is Title III and Title V. Title III specifically addresses sources that emit 10 tons per year of any hazardous air pollutant (HAP), 25 tons per year of total HAPs or some lower amount established through rulemaking. Title V of the CAAA require each state to regulate new and existing emission sources through a program of operating permits. The operating permits will include all state and federal air quality requirements in a single document. The permits have the potential to significantly limit operation flexibility through limitations on fuels, raw materials, production rates, and hours of operation. The first critical step in the permitting process in inventorying your process emissions. Estimates through mass balances have been used in the past and are now inadequate. The methods for determining formaldehyde, acrylate, and phenol emissions and their limitations as well as the current status of their requirements will be discussed. The reduction of HAP emissions can be achieved through various control strategies; the most desirable would be through materials substitution. In many instances, materials substitution is not an alternative and some type of control will need to be applied to effluent. The comparison of two controls strategies, incineration, and biofiltration will be made. The status of the combined EPA study on formaldehyde will be presented.