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Kolmetz.com - Cooling Tower Monitoring 10 (Page 7)

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Kolmetz.com - Cooling Tower Monitoring 10
Available Control Technology (BACT), and (2) Assess the impact (with air dispersion modeling)
on the appropriate NAAQS. Generally, monitoring, record keeping, and reporting requirements
are established in the PSD permit.

Non-Attainment New Source Review (NSR) Permits: The NSR permit program originated from
the 1977 Clean Air Act Amendments. The NSR program is a permitting program for large new,
modified, or reconstructed sources in "dirty" air areas (areas that are not in compliance with
National Ambient Air Quality Standards [NAAQS]). The NSR program was intended to
regulate stationary sources in non-attainment areas and to improve the air quality in these areas.

For large new, modified, or reconstructed sources, the emissions from all sources must be
evaluated, including cooling towers. Cooling towers emit PM10 and VOCs (or HAPS) and if
included in a NSR permit review, these emission sources would be required to: (1) Install
Lowest Achievable Emission Rates (LAER), and (2) Obtain offsets for the emissions increases
associated with the project. Generally, monitoring, record keeping, and reporting requirements
are established in the NSR permit.

Title V Operating Permits: The Title V Operating Permit program originated from the 1990
Clean Air Act Amendments. The Title V Operating Permit is required for all "major" sources of
air pollution, and identifies emissions limits, regulatory requirements, monitoring and record
keeping provisions, and reporting requirements. For a major source that includes a cooling
tower, the emissions associated with the cooling tower must be assessed and included in the Title
V Operating Permit. Generally, monitoring, record keeping, and reporting requirements are
established in the Title V Operating Permit.

National Emission Standards for Hazardous Air Pollutants (NESHAPS) Regulations: The
NESHAPS Program originated from the 1970 Clean Air Act Amendments, and was radically
changed in the 1990 Clean Air Act Amendments. The Clean Air Amendments require the
Environmental Protection Agency to develop the NESHAPS regulations. One of these
NESHAPS is the Hazardous Organic NESHAPS (HON), which requires the installation of
Maximum Achievable Control Technology (MACT) at all affected organic chemical
manufacturing facilities. The HON contains specific requirements for cooling towers, including
monitoring, record keeping, and reporting provisions.

Toxic Chemical Release Inventory (TRI) Reports: Reporting TRI Releases on an annual basis is
required by Section 313 of the Emergency Planning and Community Right-to-Know Act
(EPCRA, or Title III of the Superfund Amendments and Reauthorization Act [SARA] of 1986).
Reporting of annual TRI releases was intended to provide the public with information regarding
releases of the identified compounds in their communities, and to assist the EPA in determining
the need for additional regulations. The TRI rules include a list of chemicals and classes of
chemicals that must be reported, many of which may be present in cooling water systems. For
affected facilities, monitoring and assessing cooling tower emissions is required to maintain
compliance with the TRI rules.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Release
Reports: CERCLA was passed in 1980 and requires the person in charge of a facility to

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