Editor’s Note: The Allegheny County Health Department periodically updates its website to include documents related to air quality enforcement actions. As part of our watchdog work, GASP monitors this webpage and reports on the air quality violations posted there. Air Quality Violations Lead to $46K Fine for Synthomer Allegheny County Health Department (ACHD) issued a more than $46,000 civil penalty against West Elizabeth-based Synthomer - a Title V facility that produces synthetic hydrocarbon resins - for exceeding emissions limits. According to an Oct. 20, 2025, enforcement order just recently uploaded to the ACHD docket, a 2023 compliance test of a C-5 Thermal Oxidizer stack revealed Synthomer blew past emissions limits in violation of the facility’s installation permit. ACHD said Synthomer continued to operate under similar conditions for three months, making it out of compliance with its permit. A $46,400 fine - payable to the Allegheny County Clean Air Fund - was assessed. Here’s the enforcement order  for folks who’d like to take a deeper dive. ACHD Revokes Green Development’s Asbestos License, Takes Enforcement Action Against Wilkinsburg Borough for Abatement Issues The Allegheny County Health Department revoked the asbestos abatement license of Green Development after inspections revealed the company violated various Article 21 provisions.  According to the Enforcement Order, Wilkinsburg Borough contracted with Green Development to demolish several abandoned houses in the borough. In the enforcement order filed against the company and Wilkinsburg Borough on Dec. 5, 2025, but only recently uploaded to ACHD’s docket, both were ordered to stop all demolition work on several properties in the municipality. This wasn’t the first time that Green Development had enforcement action taken against it: Its permit was first suspended in May 2025  for similar infractions. “Green Development has not shown a willingness or ability to comply with Article 21 asbestos abatement requirements,” the enforcement document noted. You can read the  entire enforcement order here. ACHD Takes Enforcement Action Against TNT Excavating, Wilkinsburg Borough for Myriad Asbestos Abatement Violations ACHD took enforcement action against TNT Excavating and Wilkinsburg Borough for myriad asbestos-abatement related violations in 2025. According to the enforcement actions,  Wilkinsburg Borough contracted with TNT to conduct asbestos abatement in December 2025, despite TNT not having a proper license. According to the enforcement actions, TNT and Wilkinsburg demolished several structures without a permit and without first notifying the department. You can read the Dec. 5, 2025, enforcement action here . You can read the July 23, 2025  enforcement order here. ACHD Takes Enforcement Action Against Wheaton & Sons for Permit, Dust Issues ACHD in March 2025 took enforcement action against Braddock-based Wheaton & Sons for failing to apply for a permit to operate regulated equipment. According to the enforcement order: Wheaton and Sons Inc. is an establishment primarily engaged in fabricated structural metal manufacturing operations. ACHD observed machining processes, including two plasma cutters, one laser cutter multiple press brakes, bandsaws, curving rolls and punching centers. The plasma cutter operates on a water table, but ACHD saw no other dust control measures. The company was ordered to stop all work and provide proper documentation to the department. You can read the entire enforcement order here . LHT Coraopolis Terminals Fined Nearly $6K For Abrasive Blasting Violation ACHD issued a $5,890 for performing abrasive blasting without a permit in August 2024. In Allegheny County, abrasive blasting projects totaling more than 10,000 square feet require a permit application with fee and a 30-day notification to be submitted prior to the commencement of abrasive blasting activities.  Coraopolis Terminals (and contractor Hannahoe Painting) performed abrasive blasting of 18,056 square feet of or abrasive blasting without an ACHD issued abrasive blasting permit.  You can read the entire enforcement order here. LHT Neville Island Terminal Filed $840 For Late Annual Compliance Certification ACHD on Oct. 25, 2025, fined LHT Neville Island Terminal $840 for failing to submit its 2023 annual certification of compliance as required under the terms of its Title V Operating Permit.  The enforcement order noted the company filed the certification 59 days late. You can  read the entire enforcement order here. Sailor Excavating and Paving Fined $1,100 for Failing to Control Dust ACHD on Sept. 9, 2025, fined Sailor Excavating and Paving $1,100 following an investigation spurred by dust complaints. Here’s an excerpt from the enforcement order: ACHD observed loaded dump trucks driving up and down a steep dirt roadway. The dump trucks were carrying and dumping material across the worksite to grade the lot. Fugitive emissions were created by the trucks driving on the dirt roadway that was not wetted. The ACHD Representative witnessed fugitive dust from the roadway crossing the property line and entering into public space. For the uninitiated: Article 21 - our local air quality regulations - prohibit operation of sources that allow the release of air contaminants into the open air or to cause air pollution. You can read the entire enforcement order here. P&W Motors Fined $1,800 Over Operating Without a Permit ACHD issued an $1,800 fine against P&W Motors on Sept. 12, 2025, for operating without a proper permit.  Here’s what happened:  The building now owned by P&W Motors at 720 Gross Street in Pittsburgh was formerly occupied by West Penn Hospital Foundation Research Building, which operated two boilers and an emergency generator - equipment that requires a permit. On May 10, 2024, ACHD inquired about unpaid annual maintenance fees only to find out the building had been sold and P&W Motors intended to tear the building down. On Feb. 14, 2025, ACHD emailed P&W to inform them that they would need to transfer the permit to the new owners or render the equipment inoperable and terminate the permit.  On April 25, 2025, ACHD again emailed company representatives to inform them that the permit must be transferred and renewed or that the equipment be rendered inoperable and the permit terminated.  While ACHD set deadlines for P&W to make that decision, the enforcement order notes that as of the date of the enforcement order, “P&W BMW of Pittsburgh failed to transfer ownership and renew the operating permit for the regulated equipment at 720 Gross Street.” You can read the entire enforcement order here.

The U.S. Occupational Safety and Health Administration (OSHA) has fined U.S. Steel $118,000 for safety violations stemming from the deadly August explosion at the Clairton Coke Works. OSHA documents show that the company was cited 10 times - nine of those were related to subpar safety procedures and employee training, and one was for failing to provide the agency with required reports as required. The fines were first reported by the Pittsburgh Tribune Review . Additionally, one of U.S. Steel’s contractors - MPW Industrial Services - was also cited nine times and fined $68,000. GASP staff is currently reviewing the citations. You can read the U.S. Steel citations here . You can read the MPW citations here . We continue to follow this issue closely. For more information on the explosion, visit GASP’s resource page here.

A couple of weeks ago we blogged  about the U.S.  Environmental Protection Agency’s revision of the New Source Performance Standards (NSPS) for natural gas-fired combustion turbines. In that blog, we noted EPA’s decision not to quantify human health benefits  that might accrue from reductions in such turbines’ emissions of oxides of nitrogen (NOx) and fine particulate matter PM2.5”) under the new standards as part of the cost-benefit analysis that it performed for the standards.    EPA’s decision drew protests from environmentalists (one headline, from the New York Times:  “ Trump’s E.P.A. Has Put a Value on Human Life: Zero Dollars ”) and, for the revision of an NSPS, a very unusual amount of media coverage.   We committed to examining the EPA's decision to determine its validity and provide an update. Here ’s what we found.   As we blogged earlier, NSPS are promulgated pursuant to section 111 of the Clean Air Act.  Section 111, as amended in 1977, does not  require that expected human health benefits from a revision of an NSPS be quantified and worked into a cost-benefit analysis. Rather, the Act only requires EPA to take into account the cost of implementation and the “ nonair  quality health and environmental impact and energy requirements” when it revises or promulgates an NSPS.     Thus, you could argue that if EPA’s recent change of course places the value of human life at zero, the 95 th  Congress beat them to it when they revised section 111 in 1977. Indeed, it appears that before 1993 (more on that date below) EPA did not quantify and consider quantified human health benefits that would follow its proposed revisions to the NSPS; nor did the courts that reviewed EPA’s new or revised NSPS .      You could even argue that when EPA quantified health impacts from NSPS and worked them into its cost-benefit analyses in the past, it effectively rewrote section 111.   Which got us wondering: If EPA’s practice of performing cost-benefit analyses for new or revised NSPS does not come from the Clean Air Act, where does it come from?   The answer is Executive Order 12866, which President Bill Clinton issued in 1993.    Executive Order 12866 generally requires that when a federal agency (including EPA) promulgates or revises a regulation, the agency must assess the anticipated costs and benefits of the regulation and may adopt them only when the anticipated benefits from the regulation exceed the anticipated costs.    Executive Order 12866 also requires that for any “significant regulatory action” (meaning, one that will have an impact on the economy of at least $100 million), the agency proposing the regulation must submit a written cost-benefit analysis to the Office of Management and the Budget.   Executive Order 12866 does not require that all, or even any, expected benefits from a regulatory action be quantified and even acknowledges that some expected benefits from a regulatory action might not be able to be quantified.   That means that, strictly speaking, the Clean Air Act does not require that EPA do a cost-benefit analysis at all when it promulgates or revises an NSPS. But the Act does not prohibit it either. If EPA does such an analysis pursuant to Executive Order 12866, it can quantify the human health benefits from the new or revised NSPS or not, as it sees fit, in its analysis.    All of this gives EPA a lot of leeway.    How has EPA used that leeway, you wonder?  Naturally, it depends on who’s in charge.    We went back through several years’ worth of NSPS revisions (all the way back to the second half of the Obama Administration) and found that EPA has been inconsistent, not only about what quantified health benefits it includes in its cost-benefit analyses for new or revised NSPS, but also about whether or not it conducts such analyses at all.    The first thing we learned was that when EPA has proposed new or revised NSPS that are not “significant regulatory actions” within the meaning of Executive Order 12866 it has not  included quantified human health benefits in the cost-benefit analyses that it performed for those NSPS, regardless of who the President was.    Was EPA placing the value of human life at zero when it promulgated those new or revised NSPS?    Not really.    It was only performing the assessments that were required of it by the Clean Air Act, and to a lesser extent, Executive Order 12866. The dollar value of the human health benefits that would be created, if any, were beside the point.   Second, we learned that even in the context of cost-benefit analyses done for NSPS that qualify as “significant regulatory actions,” EPA’s consideration of quantified human health benefits (as well as “climate benefits”) has been inconsistent.    When we looked at the analyses for recent NSPS, we found:   Under President Biden, EPA quantified human health benefits from reduced emissions that would follow revised NSPS and included them in the cost-benefit analyses it performed for NSPS that qualified as “significant regulatory actions.” During President Trump’s first term, EPA did not promulgate or revise any NSPS so did not trigger Executive Order 12866’s cost-benefit analysis requirement. Under President Obama, when EPA promulgated new rules for municipal solid waste landfills in 2016 to require the collection of methane they produce, it quantified and considered the “global social benefits” of reductions in direct methane emissions; it did not quantify or consider the costs or harms that would come from burning that methane. When EPA promulgated new rules for residential wood heaters, hydronic heaters, and forced air furnaces in 2015, it considered quantified human health benefits of reduced PM emissions, but not the quantified benefits of reduced NOx emissions or climate benefits that would flow from the rules. When EPA promulgated new rules for oil and natural gas wells in 2012, it determined that the benefits that would flow from reduced emissions of PM, NOx, hazardous air pollutants, and methane under the rules could not be quantified in a “defensible way.”  Nevertheless, it finalized the rule.   “One conclusion that may be drawn here is that EPA’s regulatory agenda drives its cost-benefit analyses; the analyses do not drive the regulatory agenda,” said GASP Senior Attorney John Baillie.  “A pro-industry administration will find a way to promulgate less restrictive Clean Air Act regulations, and a pro-environment administration will find a way to regulate more aggressively.  Until Congress or the Supreme Court clarifies exactly what factors must be considered in a cost-benefit analysis for a Clean Air Act regulation, this will continue to be the case.”

There’s been yet another equipment breakdown at U.S. Steel’s Clairton Coke Works facility, the Allegheny County Health Department (ACHD) announced in a press release Thursday. Here’s what the release said: According to the release, ACHD received a call from U.S. Steel regarding a breakdown of pollution control equipment at Clairton Coke Works. A breakdown happens when equipment isn't working properly and releases more pollution than normal. This can happen when equipment fails, during power outages, or other unexpected problems happen. Our initial understanding is that Control Room 2 went offline due to a breakdown beginning on January 27 at approximately 8:05 pm. As a result, Control Rooms 2 and 5 were not processing coke oven gas and the partially processed coke oven gas was combusted at the facility. The outage lasted until January 28 at approximately 8:20 pm. At this time, equipment is back online. ACHD monitors recorded elevated readings of H2S, SO2, and PM2.5 at the Liberty monitor site on the morning of January 28. The highest readings were between 6 and 9 am when there were light winds from the southwest and a weak temperature inversion which can trap pollutants to the surface. The elevated readings were not high enough to cause a 1-hour or 24-hour exceedance of any air quality standard. During this event, Hydrogen Sulfide (H2S) levels elevated at ACHD monitors in the surrounding areas. H2S is a colorless gas with a strong "rotten egg" odor. According to the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), short-term exposure at high concentration levels (over 2 ppm) can cause symptoms such as headaches, nausea, dizziness, eye or throat irritation, and respiratory discomfort, particularly for individuals with asthma or other underlying lung conditions. The highest hourly concentration recorded was 0.019 ppm. Currently, ACHD has limited information regarding the cause of the breakdown but has requested more information and has inspectors onsite inspecting coking operations. U.S. Steel is required to submit a breakdown report within seven days. There is also an additional 30-day reporting requirement. Currently there is no indication of a long-term health emergency; however, ACHD will continue to closely monitor air quality in and around Liberty, Clairton, and North Braddock. Residents in the affected area who experience prolonged and intense symptoms are encouraged to seek medical care. The public is also encouraged to use the Air Quality Dashboard  and the Hydrogen Sulfide Dashboard  for hourly updates. ACHD indicated that it will continue to investigate the breakdown and provide information to the public as it becomes available. GASP thanks ACHD for the public disclosure. We will keep you posted as more information becomes available.

Trump’s EPA on Thursday announced the revocation of what’s known as the 2009 Endangerment Finding - one that resulted in greenhouse gas emissions regulations for motor vehicles and engines.   The Endangerment Finding is the legal prerequisite EPA used to regulate emissions from new motor vehicles and new motor vehicle engines. Without the Endangerment Finding, the EPA would not have legal authority under Section 202(a) of the Clean Air Act (CAA) to set standards for greenhouse gas emissions.   Without this finding, EPA loses its statutory authority to address the very real and accelerating threat of climate-altering pollution not just from our vehicles, but from all sources. Like so many decisions from this regime, the rationale for this move seems to be based on how industry will benefit from this repeal – how it will supposedly save money and increase "consumer choice." By contrast, the proposal was absurdly light on any details about the devastating impact it will have on the environment and, more importantly, on human health. It’s clear the EPA has lost its way. The EPA's mission is to protect human health and the environment. Yet the systematic rollback of regulations like the endangerment finding and the willful disregard for scientific evidence, represents a truly dark age for this agency. We are witnessing an abandonment of the EPA’s core purpose, a betrayal of the public trust, and a dangerous gamble with the health and well-being of current and future generations. Local leadership is crucial now.   GASP urges our municipal, city, county, and state policymakers to continue to treat climate change as the very real threat to public health that it is and to continue to act accordingly though prioritizing electrification of municipal fleets and finalizing and acting on climate change plans. Pretending the threat does not exist is simply not an option.

Editor’s Note: The Allegheny County Health Department periodically updates its website to include documents related to air quality enforcement actions. As part of our watchdog work, GASP monitors this webpage and reports on the air quality violations posted there. Longstanding emissions and maintenance issues led to Allegheny County Health Department (ACHD) to issue more than $276,000 in fines against Braddock-based Magnus Products. Little bit of background: Magnus Products owns and operates a facility that receives by-products from U.S. Steel’s Edgar Thomson facility, including furnace flue dust, slag and sludge, mill scale, and coke fines and forms the moist mix into briquettes.  Those finished briquettes are piled onsite with a radial stacker and then loaded onto railcars and sent back to Edgar Thomson to be used in the blast furnaces.  Emissions from the rotary kiln - the piece of equipment at the center of the enforcement action - are controlled by a cyclone and a fabric filter. Got it? Good - now let’s get back to that enforcement order, issued by ACHD on Nov. 10, 2025, but only recently uploaded to the department’s docket. In addition to missing deadlines associated with the submission of required annual and semi-annual reports, ACHD said the company exceeded myriad emissions limits - some by more than 1,900 percent.  The enforcement order also alleges that Magnus failed to consistently operate its cement silo bin filter with good air pollution control practice resulting in excess emissions.  “Magnus operated the rotary kiln without a complaint stack test in violation of permitted limits resulting in excess emissions of volatile organic compounds and particulate matter for 22 months,” the document reads. Here's an excerpt: ACHD representatives observed multiple chains with no chain guards.  ACHD representatives observed excessive amounts of cement accumulation on the top of the cement silo bin filter. ACHD representatives also observed cement accumulation on the cement silo hand railings, cement silo walkway, and the wall of the adjacent building (see Appendix A).  ACHD representatives requested that Magnus representatives open the cement silo bin filter door so ACHD could inspect the individual bags in the cement silo bin filter. Magnus representatives could not initially open the door because cement had accumulated around the door and door frame. Magnus utilized tools to remove cement accumulation to open the door for inspection. During the inspection, ACHD representatives found a bag was defective, and a Magnus maintenance worker confirmed the bag was defective.   ACHD representatives then requested to review the Magnus cement silo inspection records. ACHD representatives reviewed the cement silo inspection records for March 2025, through April 9, 2025. Inspection records indicated "ok" for each inspection. ACHD representatives informed Magnus that, due to the identification of a defective bag in the cement -6- silo bin filter and amount of cement deposition in the area, it was ACHD's belief that the cement silo was not inspected with any routine frequency and the records indicating compliance were  not valid.   You can read the entire enforcement order here. Meanwhile, court documents reveal that U.S. Steel ended its relationship with Magnus in October 2025 and filed suit against the company two months later, accusing it of breach of contract.

Editor’s Note: The Allegheny County Health Department periodically updates its website to include documents related to air quality enforcement actions. As part of our watchdog work, GASP monitors this webpage and reports on the air quality violations posted there. New documents uploaded this week to the Allegheny County Health Department’s website show that U.S. Steel was issued more than $359,000 in stipulated penalties for air quality violations that occurred at its Clairton Coke Works facility. The demands - issued  Oct. 17, 2025   and Dec. 18, 2025  - called for U.S. Steel to pay $271,775 and $85,775, respectively, and cover violations made in the first and second quarters of 2024 (yes, the violations are from 2024 - and yes, they are the latest such penalties). The documents show that the lion share of the penalties were for pushing and charging violations. Interestingly, this isn’t the first time U.S. Steel has been tagged for pushing violations, specifically: ACHD in 2024 issued $2 million in penalties against the company for hundreds of uncontrolled pushes.  That issue - like so many others related to U.S. Steel enforcement actions - is still winding its way through the appeals process. GASP continues to follow enforcement issues closely and will keep you updated as more information is posted to ACHD’s enforcement docket. A donation can help sustain it!

At GASP, we’ve long believed our strength lies in the people who help us fight for cleaner air in southwestern Pennsylvania. Today, we are absolutely THRILLED to introduce two incredible new additions to our Board of Directors: Dr. Rachel Wojcik  and Dr. Nesta Bortey-Sam . Additionally, two board members – Kate St. John and Marla Ferency – were re-elected. “Both Rachel and Nesta bring a wealth of scientific and medical expertise that will be invaluable as we continue to push for better air quality and public health protections in our region,” GASP Executive Director Patrick Campbell said. GASP President Jonathan Nadle agrees Rachel and Nesta are great additions to the board, adding, “They also are really nice people.  It’s been a pleasure getting to know them and we look forward to having a long, productive relationship.”   Meet Nesta Bortey-Sam Nesta is a powerhouse in the world of toxicology and public health. He serves as an assistant professor in the Department of Environmental and Occupational Health at the University of Pittsburgh School of Public Health. His work is all about the how and why —specifically, how environmental exposures lead to disease.  Nesta is part of a team studying how indoor and outdoor pollutants affect asthma severity right here in Allegheny County. He’s using advanced techniques to track pollutants back to their sources, helping us understand exactly what is in our air. Another major focus of his research involves prenatal exposure to toxins and how they affect birth outcomes and long-term health. Meet Rachel Wojcik If there’s anyone who understands the direct impact of air quality on our lungs, it’s a pulmonary specialist. Rachel is a physician and clinician-educator specializing in pulmonary and critical care medicine. After completing medical school at the University of Colorado, she moved to Pittsburgh for her residency and fellowship training—and we are so glad she stayed! She is passionate about bridging the gap between clinical medicine and environmental advocacy. Her goal is to bring vital education regarding air pollution and climate change to fellow physicians and the local community. “As southwestern Pennsylvania continues to face unique air quality challenges, having a board that combines medical frontline experience with cutting-edge toxicological research ensures that GASP remains a leader in science-based advocacy,” Campbell added. Please join us in giving Rachel and Nesta a big, warm welcome to the team. We can’t wait to see the impact they’ll make.

GASP on Wednesday attended the Allegheny County Board of Health meeting to ask members to use their authority to push the Allegheny County Executive's office to update the Air Pollution Control Advisory Committee. Here's what our Executive Director Patrick Campbell said: Good afternoon. My name is Patrick Campbell, Executive Director of the Group Against Smog and Pollution (GASP), a nonprofit dedicated to advancing healthy air quality since 1969. I appreciate the chance to speak with you today because we share a common goal: ensuring strong and effective oversight of air quality in Allegheny County. Right now, the Air Advisory Committee is in a difficult position. Every member is serving on an expired term, and the committee has not met since late last year. This uncertainty has limited its ability to function as intended— as a vital link bridging technical expertise, community voices, and policy. Over the past year, the committee often lacked a quorum and struggled to advance recommendations. While we understand the need for diverse representation—including public health experts, industry, and impacted communities—the current roster appears weighted toward industry, which raises concerns about balance and credibility. GASP respectfully urges the Board of Health to use its authority to encourage the County Executive’s office to prioritize these appointments and restore the committee’s effectiveness. We believe this is an opportunity to strengthen collaboration and ensure the advisory process reflects the broad interests of our community. Please know that GASP stands ready to assist in any way—whether through outreach, technical input, or supporting recruitment efforts. Thank you for your time and for your commitment to protecting public health. Stay tuned! We continue to follow this issue closely and will keep you posted!

The U.S. Environmental Protection Agency (EPA) earlier this month published a final rule that revises the New Source Performance Standards (NSPS) for natural gas-fired stationary combustion turbines.    Such turbines are ubiquitous, including in southwestern Pennsylvania.    They generate electricity at power plants (and, increasingly, data centers) and drive heavy mechanical equipment at industrial facilities (including natural gas compressor stations).   The NSPS are emission standards for new, modified, and reconstructed sources that apply nationwide and ensure that the pollution controls on such sources are (more or less) up to date when they are installed.    Emission rates established by an NSPS are to be based on the use of the “best system of emission reduction” (BSER, remember that acronym!) as determined by EPA.    The revisions to the NSPS for natural gas-fired stationary combustion turbines that were published last week are codified as Subpart KKKKa; they revise Subpart KKKK, which had been in effect since 2006.   Subpart KKKKa garnered an unusual amount of press coverage for an NSPS revision, even before it was published in final form. Why, you wonder? Because when EPA promulgated Subpart KKKKa it stated that it would not attempt to monetize any claimed health benefits from the reductions in emissions of oxides of nitrogen (NO x ), fine particulate matter (PM 2.5 ), and sulfur dioxide (SO 2 ) that will result from the revised standards as part of the impact analysis that it performed for the revisions.    EPA failure to do so in this instance appeared to be a break from long-standing practice that endangers the health protections provided by the Clean Air Act.    You can read about the issue in the New York Times , on NPR , and in the Associated Press .  On the other hand, EPA claimed that its decision not to include health benefits in its impact analysis is justified because estimates of such benefits are too speculative to serve as a basis for rulemaking under the Act.    It bears mention that a 1973 decision by a federal Court of Appeals  established that EPA is not  required to perform a cost-benefit analysis when it promulgates or revises an NSPS.   What caught our interest about the articles covering Subpart KKKKa were their suggestions and claims that Subpart KKKKa’s revisions weakened emission standards for natural gas-fired stationary combustion turbines.    It is rare for a revised NSPS to weaken emission standards.   And what we learned was that those suggestions and claims were – mostly – not true.   In fact, for most categories of natural gas-fired stationary combustion turbines Subpart KKKKa either retains existing NO X  emission limits or decreases them.  Notably, in establishing Subpart KKKKa’s emission limits, EPA determined that BSER for new, large, high-utilization turbines required the use of selective catalytic reduction (SCR); forcing the operators of turbines to install and operate SCR has been a longstanding goal of environmentalists .    However, EPA rejected the notion that SCR was BSER for all other  categories of turbines, based on either technical infeasibility (SCR often cannot be added on to modified turbines and is not as effective for turbines that do not operate in a steady state) or high cost per ton of NO X  emissions that SCR would be able to remove.    For those other categories, EPA determined that BSER is combustion controls, based on NO X  emission rates guaranteed by the manufacturers of new turbines or the manufacturers of commercially available add-on combustion controls (for modified turbines).    And so, what’s the result? This chart compares allowable NO X  emission limits under the old Subpart KKKK and new Subpart KKKKa and shows how NO X emission limits for some categories of turbine decrease under Subpart KKKKa.   These decreases are notwithstanding EPA’s failures to credit the health benefits from projected emissions reductions under the revised rule and to require more than one category of turbine to use SCR: Subpart KKKK NO X  Emission Limit for Categories of Natural Gas-Fired Turbines (expressed in parts per million) Subpart KKKKa NO X  Emission Limit for Categories of Natural-Gas Fired Turbines(expressed in parts per million) New/Large…………………………………15 New/Large/High Utilization………………..5 New/Large/Low Utilization/High Efficiency…………………………………25 New/Large/Low Utilization/Low Efficiency…………………………………..9 New/Medium………………………………25 New/Medium/High Utilization…………...15 New/Medium/Low Utilization……………25 New/Small/Electric Generating……………42 New/Small………………………………...25 New/Small/Mechanical Drive…….………100 Modified/Large…………………………….15 Modified/Large/High Efficiency……….25 Modified/Large/Low Efficiency………….15 Modified/Medium………………………….42 Modified/Medium……………………...…42 Modified/Small……………………………150 Modified/Small………………………….150   The new, higher limits on NO X  emissions from new and modified large high-efficiency turbines allowed under Subpart KKKKa and in boldface above are based on EPA’s finding that the “only commercially available combustion controls” for such turbines are guaranteed at 25 parts per million NO X by their manufacturers.    “How much credence does that finding deserve?” asked GASP’s Senior Attorney, John Baillie, “Not much.”   Baillie noted that in  2005, when Subpart KKKK was still a proposed rule , EPA wrote:   Many manufacturers guarantee NO X  emissions of 15 ppm … for large natural gas-fired turbines, and a few even guarantee NO X  levels at or below 9 ppm….  In addition, we have gathered a number of source tests which confirm that these turbines can achieve these levels without the use of add-on controls. Therefore, this emission limit may be achieved by most large natural gas combustion turbines without the use of add-on controls. Stay tuned, there is a good chance all this ends up in court and if so, we’ll report on that. Also, we intend to determine just when EPA started quantifying projected health impacts from the emission reductions resulting from new regulations and write about it.