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- - - - - - - - - .. - - - - - - - .. .- IS?;! Division: Air Pollution Control Division JSI&eS M. Lents, Director L periodic unannounced inspections of the facility. Although only PH emissions can be assessed visually by the inspector, an indirect assessment of compliance can be made by examining the condition of the control equlpaent. operating procedures and records kept by the source. A stack test can also be performed to check emIssion limits, but usually requires prenotification of the source snd the results are not available for several days to weeks afterward. 2. Continuous monitoring of emissions, either directly (stack sampling monitors) or indirectly (material or fuel monitors). Continuous monitors are required only on speciffc new sources. For all other sources, inspections are the only compliance tool. Compliance also depends on two other aspects of enforcement: 1. Legal action or other means of discouraging willful violations of reaulations. It costs a source to control air pollutants; enforcement actions should be costly and likely enough to encourage the source to comply as the least costly (or difficult) route. 2. Minimizing legal exceedances, such as those which occur duri~g startup, shutdown, upsets and malfunctions. Obviously, control equipment is a subject to problems as process equipment, but when emissions from a single upset can exceed the total annual controlled ea1ssion level, the frequency, cause, and corrective action associated with such incident must be assessed. The trends in air quality management for this decade now seem fairly clear. In nonattainment areas, no new major source (greater than 100 tons per year controlled emissions) have been constructed during the 1980's~ although existing major sources have expanded; since emissions fro. major sources and major modifications in uonattainment areas must by regulation be offset, these emissions are at as h1gb a level as they will ever be, even if new major sources do, in the future, plan to locate in these areas. Hinor source growth in these areas (lncluding mobile sources) continues and is expected by sheer numbers to increase overall emissIons. The anticipated phase-out of existing major sources has not occurred, probably due to overall economic condtitions and the difficulty and costs associated with new facilities (including offsets and .ore stringent regulations). Major sources are locating in attainment areas, which are accommodating this growth, so far, within the bounds of the strict allowable incremental ambient air concentration increases allowed by the Prevention of Significant Deterioration (PSD) portion of the new source review program. the one area where PSD limite, particularly those for air quality related values in national parks and other Class I areas, as, have already been reached is the 011 shale development area centered in Rio Blanco County On the Western Slope. '!bis area will be a proving ground for nearly all the PSD concepts and policies. Increases in required NOx and S02 control for all new sources will be likely 8S air quality managers focus on an acid depoSItion. Fine particulate controls in nonattainment areas will receive attention, but interest should also be retaiued in PMT emissions statewide as part of the welfare aspects of air pollution impacts. Increases in VOC controls can be anticipated in ozone nonattainment areas, but is less likely to occur statewide. CO controls for stationary sources, with the exception ~f refineries, is likely to reaain too costly and les8 urgent a problem, even in nonattainment areas" since mobile sources are c~nsidere4 the _ain co proble. in ,such areas. Control of toxic and addltl9081 hazardous pollutants will be pursued and exposure to such pollutants will begin to decrease ooce these limits ar~ enacted. Levels of all other noncriteria pollutants will continue to increase, but no immediate effects are anticipated. -33- >;,,,,,,',>,,.,+