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What’s the source?
Under the CAA, EPA regulates “sources” of air emissions. But what exactly is a “source.” While the actual regulated source may be different depending on the program, a source is simply a collection of “emission units” that are grouped together based on functionality and proximity. And an “emission unit” is a just piece of equipment or an operation that emits air pollutants.
For the 40 CFR Part 60, 61, and 63 source category standards, EPA defines the affected source (sometimes called an affected facility) in each standard. Different standards may define the same or a similar affected source—or even an overlapping affected source. At the same time and independently, each source is defined on a case-by-case basis for new source review (NSR). [40 CFR Parts 51 and 52].
Because multiple source category standards and NSR requirements may overlap on the same piece of equipment or operation, compliance becomes a bit more complex. All applicable requirements must be met, and this is the source of much confusion with CAA compliance. For more compliance morsels, visit our website.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
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