Applicability of EPA cooling tower NESHAP Regulations to facility cooling towers

 EPA Subpart Q NESHAP Industrial Cooling Towers:   The facility is not a major source as defined by Subpart Q.  Therefore it is not subject to the federal NESHAP requirements.  FACILITY Hazardous Air Pollutants are summarized on a rolling 12 month basis at the following link:  FACILITY HAP Emissions.  

Major source means any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combination of hazardous air pollutants.

 FACILITY Cooling Tower Locations and Estimated Capacity

  a) Vertical cooling tower southeast exterior of building A; Non-contact cooling water from the ____________ process.  The water capacity of cooling units = ___ gallons.

 b) Vertical cooling tower southeast of building B: Non-contact cooling water from _______________ process.  The water capacity of cooling units = ___ gallons.

        This cooling tower has an overfill tank that discharges to surface water.

 FACILITY estimates that each tank would potentially get drained once a year.