Guam
EPA
Air
Pollution Control Program
The
following information was provided by Guam EPA's Barbara Torres and Pete Cruz
during the September 14, 1999, meeting of the Guam Hotel and Restaurant Association
(GHRA) Engineering Committee Meeting. (Links are provided by PCR Environmental,
Inc.)
- Introduction:
- Guam
Air Pollution Control Act (Public
Law 24-40)
- Guam
Air Pollution Control Standards and Regulations (Public Law 24-322)
- Federal
Clean Air Act (Last Amendment was in 1990)
- 40
Code of Federal Regulations (CFR) - Parts
50 - 100
- Stratospheric
Ozone Protection Regulations - Title VI of
the Clean Air Act, and 40 CFR Part 82.
- Regulations
and Statutes
- 40
CFR Part 82, Subpart A - Production and Consumption Controls (§604, §605)
- 40
CFR Part 82, Subpart B - Servicing of Motor Vehicle Air Conditioners
(§609)
- 40
CFR Part 82, Subpart C - Nonessential Bans (§610)
- 40
CFR Part 82, Subpart E - Labeling Requirements (§611)
- 40
CFR Part 82, Subpart F - Recycling and Emissions Reduction (§608)
- 40
CFR Part 82, Subpart G - Significant New Alternatives Policy (§612)
- Class
I (CFC, i.e.. R-11, R-12) vs. Class II (HCFC, i.e.. R-22)
- Recover/Recycle/Reclaim
- Prohibitions
- Leaking
Requirements - Applicable to all appliances with more than 50 pounds
of freon. Trigger rates for a 12-month period:
- Commercial
Refrigeration - 35%
- Industrial
Process Refrigeration - 35%
- Comfort
Cooling - 15%
- All
other appliances - 15%
- Record
Keeping Requirements
- Certification
Requirements
- Certified
Technicians - Section 609
- MVAC
- Certified
Technicians - Section 608
- Class I, Class II, Class III, Universal
- Phase-out/Importation
- Class
I (R-11 and R-12) - No importation allowed from other countries
(P.I., Korea, Japan, etc.). However, importation from U.S., okay
- Class
II (R-22) - Importation still okay, until 2003
- Air
Pollution Control Permitting Requirements
- Air
Permitting Regulations
- Title
V of the Clean Air Act (40 CFR Part 70
and 71)
- Guam's
Alternate Title V Permit Program (40
CFR Part 69.13)
- Guam's
Air Pollution Control Act (P.L.
24-40)
- Guam's
Air Pollution Control Standards and Regulations (P.L. 24-322)
- Current
Permit Program vs. New permit Program
- One
permit issued for all air emission sources within a facility. No
longer individual permits per unit.
- There
are permit application fees, and annual emission fees.
- All
draft permits must go through a public notice.
- Permits
are good for five years.
- Potential
To Emit: The maximum capacity of a stationary source (facility)
to emit any air pollutant under its physical and operational design.
Potential to emit can be calculated for different sources using the
AP 42 factors.
For
example: A hotel has three standby generators, two boilers, and a
dry cleaner. The total potential to emit is what is calculated and
determines if the facility is a major source. For generators use AP42
Chapters 3.3 and 3.4, for boilers
use AP42 Chapter 1.3.
Major Source:
More than or equal to 100 Tons per year of any criteria pollutants
(SO2, NOx, PM10, VOC, CO, etc.)
More than or equal to 10 Tons per year of any one hazardous
air pollutant - listed in the regulations.
More than or equal to 25 Tons per year of any combination of
two or more hazardous air pollutant - listed in the regulations.
Minor Source:
More than 1 Ton per year of any criteria pollutant or hazardous
air pollutant, and not defined as "insignificant" in the regulations.
- Federal
Oversight Source is a major source, or a source subject to any
of the following federal regulations (some Federal Oversight Sources
may not be a major source):
- 40
CFR Part 52.21 (PSD)
- 40
CFR Part 60 (New Source Performance Standards)
- Subparts
D - Dc - Steam Generating Units (Boilers)
- 40
CFR Part 61 (National Emission Standards for Hazardous Air Pollutants)
- 40
CFR Part 63 (National Emission Standards for Hazardous Air Pollutants
for Source Categories)
- Subpart
M - Perc Dry Cleaners
- Subpart
Q - Industrial Process Cooling Towers
Permitting
Process:
- 60
Days completeness determination
- 30
Days public comment period
- 45
Days Federal EPA Oversight
- Non-Federal
Oversight: Local permit required
Permit Process:
- 60
Days completeness determination
- 7
Days public comment period
- No
Federal EPA Oversight
- TRANSITION
PERIOD:
All facilities must submit the initial permit applications by December
29, 1999. Transition period allows for the continued operation of existing
sources with certain conditions.