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Alternative compliance strategy for title 3 of the 1990 Clean Air Act amendments. Master`s thesis

Thesis/Dissertation ·
OSTI ID:137192

This dissertation presents the development of an alternate compliance strategy (ACS) incorporating pollution prevention and flexibility to replace traditional end-of-pipe control strategy. The ACS was based on the Hazardous Organic National Emission Standards for Hazardous Air Pollutants (HON) rule which is the first major Title 3 regulation promulgated under the 1990 Clean Air Act Amendments (CAAA). The ACS is defined by converting language in the HON rule into a performance based standard permitting regulated facilities to design compliance programs to meet the required hazardous air pollutant (HAP) emission reduction. Three evaluation methods are developed to compare the ACS to the compliance methods in the HON rule. The methods include a qualitative Evaluation Matrix, an economic analysis, and a Risk Reduction Measurement Model. An example facility was characterized using information from engineering references and a Dow Chemical ethylene oxide, ethylene glycol plant. The ACS and the reference control technology (RCT) compliance programs were applied to the example facility and the ACS reduced HAP emissions to a greater extent. The three evaluation methods were used to compare the compliance programs developed for the example facility and all three demonstrated the ACS to be a favorable compliance alternative. The ACS should be incorporated into the HON rule and other similar 1990 CAAA regulations as an alternative method of compliance. The ACS provides a major step in the progression of moving regulations from the traditional end-of-pipe treatment philosophy to pollution prevention performance based standards. (AN).

Research Organization:
Air Force Inst. of Tech., Wright-Patterson AFB, OH (United States)
OSTI ID:
137192
Report Number(s):
AD-A--294652/3/XAB; AFIT--95-010D
Country of Publication:
United States
Language:
English

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