Air Quality Management in the United States (2004) / Chapter Skim
Currently Skimming:
5 Implementing Emission Controls on Stationary Sources
5 Implementing Emission Controls on Stationary Sources
Pages 174-215
The Chapter Skim interface presents what we've algorithmically identified as the most significant single chunk of text within every page in the chapter.
Select key terms on the right to highlight them within pages of the chapter.
From page 174... ...
requirements for nitrogen oxides [NOx] , the acid rain NOx provisions, and the maximum achievable control technology [MACT]
|
From page 175... ...
. In addition to those programs, which either provide permits for, or mandate changes in, new and existing facilities and products, the CAA Amendments of 1990 also established the Title V operating permit program, which requires comprehensive operating permits for large stationary sources to record all operating requirements for a facility as a basis for tracking compliance.
|
From page 176... ...
However, regulators faced with setting a performance standard often compromise, setting a standard at a lower level than the one that can be achieved by many facilities so that the facility with the largest uncontrolled emis sions will not face an impossible task of control. As a result, marginal costs of emission reductions often continue to vary substantially among facilities.
|
From page 177... ...
PERMITS AND STANDARDS FOR NEW OR MODIFIED MAJOR STATIONARY SOURCES The CAA mandates that the states implement and EPA oversee permit programs to control and regulate pollutant emissions from major stationary sources in National Ambient Air Quality Standards (NAAQS) attainment and nonattainment areas.
|
From page 178... ...
NSPS are national emission standards that are progressively tightened over time to achieve a steady rate of air quality improvement without unreasonable economic disruption. In recognition that the 1970 goals for attainment of air quality standards would not be met and that some attaining areas required measures to prevent conditions from worsening, NSR procedures became applicable to major stationary sources in nonattainment areas and in PSD attainment areas with the 1977 CAA Amendments.
|
From page 179... ...
totaling more than 250 million British thermal units (Btu) per hour heat input, sulfuric acid plants, petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels, nitric acid plants, taconite ore processing plants, petroleum refineries, glass fiber processing plants, lime plants, charcoal production plants, phosphate rock processing plants, and fossil-fuel-fired steam electric plants of more than 250 million Btu per hour heat input.
|
From page 180... ...
However, the control technology requirements are different in attainment and nonattainment areas. Sources subject to NSR in nonattainment areas are required to use control equipment that provides the LAER and those subject to PSD in attainment areas are required to use best available control technology (BACT)
|
From page 181... ...
and can be obtained from new emission controls on, or shutdowns of, other facilities and sources. They must be real, permanent, and enforceable.
|
From page 182... ...
. The process as currently organized can lead to conflicts between the goal of implementing improved emission-control technology as quickly as possible on the basis of BACT or LAER requirements and the need for firms to know what control technology will be required for new construction or modifications to existing facilities.
|
From page 183... ...
Promulgating a design standard for existing facilities can represent a challenge to regulators because of the spectrum of operating conditions and preexisting emissions that are present in the field. Individual sources within a particular group, such as glass furnaces, might have significantly different operating temperatures and, consequently, different NOx emissions.
|
From page 184... ...
Although there are reasons for focusing regulation primarily on new facilities or major modifications -- most notably the relatively lower cost to incorporate control technology in the planned construction -- the net effect of de facto grandfathering of facilities can be a substantial source of emissions. The use of a total cap on emissions with emissions trading can provide a monetary incentive for older facil ities to reduce emissions.
|
From page 185... ...
in 1996 and 1998. These new rules modify the requirements for NSR on an existing facility and will generally make it easier for projects to be undertaken at existing facilities without triggering NSR.
|
From page 186... ...
OTHER TECHNOLOGY-BASED STANDARDS IMPOSED ON MAJOR FACILITIES In addition to the requirements for new and modified emission sources, the CAA contains explicit requirements for the imposition of emissionbased standards and emission reductions on specific types of sources regardless of whether they are new or being modified. Examples of these requirements are reasonably available control technology (RACT)
|
From page 187... ...
Maximum Achievable Control Technology As discussed in Chapter 2, the CAA Amendments of 1990 required EPA to establish emission standards that "require the maximum degree of reduction in emissions of the hazardous air pollutants .
|
From page 188... ...
Perhaps most important, older plants have not had to make emission reductions in many cases, and the emissions from these older facilities provide a substantial contribution to the emission inventories of some pollutants (see Box 5-3)
|
From page 189... ...
that are more cost-effective than the predetermined control technologies that are the basis for the standards. Such development is encouraged in the 1990 CAA Amendments.
|
From page 190... ...
COMPLIANCE ASSURANCE FOR TRADITIONAL CONTROL PROGRAMS EPA and the states rely on two primary means to ensure compliance with the emission-control requirements described in the previous sections: on-site inspection and compliance monitoring. To facilitate these efforts, the 1990 CAA Amendments enacted provisions for the Title V operating permit program, which was designed to record all relevant requirements and conditions in one document and to provide a fee structure for the states to provide resources to support the compliance efforts.
|
From page 191... ...
The complexity of the effort required to issue these permits was underestimated at the time the 1990 CAA Amendments were passed. Sources and state agencies had to pay more attention to emission data, which were not accurately recorded for many sources, to ensure that sources were properly classified as major or synthetic minors.
|
From page 192... ...
periodic source testing; (3) parametric emissions monitoring (PEM)
|
From page 193... ...
Nevertheless, given the high cost and unavailability of other monitoring methods, many of the regulated facilities in the United States rely on this method to calculate permit fees and report facilitywide emissions to agencies that develop the areawide and nationwide emission inventories. As discussed in more detail in Chapter 6, because this method assumes that emission controls placed on a facility are effective, it is not a scientifically robust way to document independently the success of AQM in reducing pollutant emissions.
|
From page 194... ...
Such systems are required by EPA for only a limited number of source categories; these include new waste incinerators, some chemical plants and petroleum refineries, utilities and large boilers subject to the Title IV acid rain emissions-trading program, and as a condition to consent decrees in enforcement actions (NRC 2000c; GAO 2001b)
|
From page 195... ...
is that a well-operated and maintained source can achieve a specified emission standard or limit under all expected operating conditions by using control equipment that has been shown through a performance test to be capable of achieving that limit (62 Fed.
|
From page 196... ...
However, there are potential disadvantages, some of which are discussed in more detail at the end of this section. The Acid Rain SO2 Emissions Trading Program Emissions trading programs were first used in the United States during the 1980s (see Box 5-5)
|
From page 197... ...
programs implemented in the 1980s were the first emission-trading programs in the United States. These programs generally were organized around measuring and trading of emission rates rather than dis crete units of emissions and shared some of four characteristics: (1)
|
From page 198... ...
. The trading program implemented in the United States was innovative because, under Title VI of the 1990 CAA Amendments, it recognized that different chemicals had different O3-depleting potentials (ODPs)
|
From page 199... ...
This FIGURE 5-1 SO2 emissions from electric utilities in the United States from 1980 to 2001. The emission reductions between 1990 and 1995 are attributable to actions taken to implement the acid rain section of the CAA 1990 Amendments and have been documented by continuous emission monitors.
|
From page 200... ...
. The compliance flexibility allows facilities with high-cost controls to purchase BOX 5-6 Savings from the SO2 Emissions Trading Program The savings obtained in the cap-and-trade program to reduce SO2 emissions from electric utilities appear to have been substantial.
|
From page 201... ...
The features that appear to have contributed to the successful design of the SO2 trading program include large emission reductions, simplicity, effective monitoring, transparency, certain penalties, and the opportunity for banking emission allowances. · Substantial emission reductions: The overall cap set by Congress for SO2 emissions represented a 50% reduction in emissions nationwide.
|
From page 202... ...
NOx Emissions Trading Programs Regional Clean Air Management The South Coast Air Quality Management District (SCAQMD) implemented the Regional Clean Air Management Program (RECLAIM)
|
From page 203... ...
to supplement the NOx emission reductions mandated under CAA provisions for RACT in Title V and the Acid Rain Program of Title IV, which did not adequately address the regional transport of NOx and O3 and the resultant nonattainment of the O3 NAAQS in the region. The OTR mandates the use of a cap-and-trade system involving large stationary sources to reduce NOx emissions during the May-to-September O3 season.
|
From page 204... ...
The program imitates the SO2 trading program in many respects, but like the OTC program, it has limited opportunity for inter-annual banking of emission allowances. Cap and Trade in Proposed Multipollutant Legislation At this writing, new programs are under consideration that would mandate further multipollutant emission reductions from the electric utility industry in a cap-and-trade program.
|
From page 205... ...
These arguments appear to be largely borne out by the results of the acid rain SO2 emissions trading program, which set a stringent national emissions cap on a criteria pollutant. As illustrated in Figure 5-2, the acid rain emissions trading program has achieved SO2 emission reductions in each of five major multistate regions of the contiguous
|
From page 206... ...
Even more significant, regions with the highest emissions, such as the north-central region, have had the largest reductions.5 On the other hand, some emission increases have occurred on smaller geographic scales (for example, some states have had emission increases)
|
From page 207... ...
Indeed, the original design for the acid rain SO2 emissionstrading program would have divided the nation into two trading zones to prevent trades that might worsen ecological problems in northeastern states. However, policy-makers recognized that a more constrained market would increase the cost, and they opted for the uniform national market approach currently contained in the statute (Hausker 1992)
|
From page 208... ...
In most previous programs, including the acid rain SO2 emissions-trading program, fairly simple principles served to guide the regulatory process. The general principle was to allocate emission allowances on the basis of historical generation (heat input at the plant)
|
From page 209... ...
Because of the nature of emission-control investments and the liabilities incurred from noncompliance, a facility will generally exceed the target reduction, meaning that emissions will be less than allowable. An emissions-trading program provides the flexibility to overcomply at one facility and to apply the unused emission allowances to increase emissions at another facility.
|
From page 210... ...
. In the case of the acid rain SO2 emissionstrading program, Congress recognized this concern and mandated that all affected facilities install and operate continuous emissions monitoring (CEM)
|
From page 211... ...
The company must then establish a mechanism for monitoring its emissions on an ongoing basis. If the managers of a facility believe that they can reduce emissions at a cost that is below the marginal cost in an established trading program, they have the incentive to join the program and attempt to sell some of the emission reductions achieved.
|
From page 212... ...
suggest that greater attention must be paid to documentation of baselines and to compliance monitoring if such programs are to succeed in reducing emissions and gain the trust and support of all parties. Voluntary Programs to Improve Permitting Processes In response to concerns that the current stationary-source permitting process inhibits new and cost-effective emissions control, several innovative permitting approaches have been attempted or proposed over the past decade.
|
From page 213... ...
of the 1990 CAA Amendments required EPA to conduct a study of consumer and commercial products by 1993 to identify products that needed regulation and then to proceed with developing control technology guidelines (CTGs) for each priority category.
|
From page 214... ...
. The Ozone Transport Commission, and the upcoming NOx SIP call trading program have the potential to achieve substantial reductions in NOx emissions.
|
From page 215... ...
· The next phase of control on HAP emissions is predicated on the conclusions of a residual risk analysis that is fraught with scientific uncertainty. · Achieving the full potential of cap and trade will require applying the technique to a broader range of pollutants, implementing a less cumbersome process for revising caps and targets, developing enhanced and more cost-effective CEM and other monitoring technologies, and guarding against deleterious geographical and temporal distribution of emission reductions.
|
Key Terms
This material may be derived from roughly machine-read images, and so is provided only to facilitate research.
More
information on Chapter Skim is available.