Lower emission limits could be coming soon to local coal-fired plants thanks to an Ozone Transport Commission (OTC) recommendation that the Environmental Protection Agency require daily limits on oxides of nitrogen on electricity generating units in Pennsylvania. The recommendation applies to coal-fired plants equipped with selective or non-selective catalytic reduction units (known as SCR and NSCR, respectively). For those who are unfamiliar: SCR and NSCR units control NOx emissions. The new recommended daily NOx limits would be at least as stringent as those in place at coal-fired EGUs in Delaware, Maryland, and New Jersey, and would theoretically force those here in the Keystone State to operate their NOx emissions control units at all times during the summer ozone season. For those who may be unfamiliar: Ozone is not emitted directly by power plants.  Rather, ozone can form when power plants’ NOx emissions are exposed to sunlight, especially during summer.  Often, ozone in one location results from NOx that is emitted by distant, downwind sources in other states. In the northeastern United States, the summer ozone season runs from the beginning of May through the end of September. Who serves on the Ozone Transport Commission and why was the recommendation made? The OTC consists of representatives of the various federal and state agencies that are responsible for regulating air pollution in the Ozone Transport Region (otherwise known as OTR) created by the 1990 amendments to the federal Clean Air Act. The commission is empowered to recommend additional air pollution controls to the EPA that it deems necessary to bring all areas of the Ozone Transport Region into attainment of the National Ambient Air Quality Standards (NAAQS) for ozone. By way of background: The Ozone Transport Region includes northern Virginia, the District of Columbia, and the states of Maryland, Delaware, Pennsylvania, New Jersey, New York, Connecticut, Rhode Island, Massachusetts, Vermont, New Hampshire, and Maine. The Ozone Transport Region was created in recognition of a simple fact: Pollution emitted in one state in the region can make attainment of the ozone NAAQS more difficult for its downwind neighbors. Within the Ozone Transport Region, sources of air pollution that lead to the formation of ozone are generally subject to stricter regulation than they might otherwise be under the Clean Air Act. “It’s unclear exactly what the Ozone Transport Commission’s recommendation would mean if accepted by the EPA,” GASP senior staff attorney John Baillie explained. That’s because regulations limiting NOx emissions from coal-fired electricity generating units in Delaware, Maryland, and New Jersey differ from state-to-state – and in Maryland, even from plant to plant within the state): Delaware – 0.125 lb/MMBtu Maryland – 0.07 lb/MMBtu – 0.33 lb/MMBtu New Jersey – 1.50 lb/megawatt hour (approximately 0.44 lb/MMBtu) It bears mention that in addition to its hourly emission limits, Maryland also requires coal-fired electricity generating units to operate all installed pollution controls during the summer ozone season. The limits on NOx emissions that are already incorporated into the Title V Operating Permits for the five coal-fired electricity generating units currently operating in southwestern Pennsylvania are, in some instances, significantly higher than those in place in Maryland and Delaware, but are – at their highest – only slightly higher than the requirement in place in New Jersey: Cheswick Station (Allegheny County) – 0.12 lb/MMBtu (if SCR inlet temperature ≥ 600° F) – 0.35 lb/MMBtu (if SCR inlet temperature ≤ 600° F) Keystone Conemaugh Station (Armstrong County) – 0.45 lb/MMBtu Conemaugh Plant (Indiana County) – 0.45 lb/MMBtu Homer City Station (Indiana County) – 0.50 lb/MMBtu Seward Station (Indiana County) – 0.15 lb/MMBtu “That means that if it’s granted, the commission’s recommendation could lead to substantially-reduced hourly limits on NOx emissions from the coal-fired electricity generating units in our region,” Baillie said. “Or perhaps not if the EPA only requires that Pennsylvania units meet New Jersey’s standard.” For those who would like to learn more, mark your calendars: The EPA will hold a virtual public hearing on the Ozone Transport Commission’s recommendation on or before Sept. 4.  More information about that hearing will be published here. #airpollution #NOx #emissions #EPA #ozone #CheswickStation

The Allegheny County Health Department (ACHD) on Thursday announced that it had commenced an air toxics monitoring study outside the Kopp Glass facility in Swissvale. According to the ACHD website, the study is designed to determine the relative health risks to the community from hazardous air pollutants such as cadmium, arsenic, and others associated with increased risks of cancer and other diseases. This isn’t the first time such a study was conducted near the site: A previous study by the U.S. Environmental Protection Agency evaluated levels of metal hazardous air pollutants at Kopp Glass and other art glass manufacturers across the county. ACHD assisted in this study. Although the EPA considered the results of that study to be within the agency’s “range of acceptability” for excess cancer risks, ACHD decided to conduct its own air monitoring on the property “to further study the health risk to the public.” ACHD indicated that the Air Quality Program began collecting samples on June 14. The department also noted that it has retained a lab and toxicologist to assist in the analysis of those samples. The new monitor is scheduled to be online through June 13, 2021 and will take and analyze a total of 60 samples. According to the ACHD website: At this time, the data demonstrate lower levels of metal hazardous air pollutants at the community monitor compared with the data taken on-site at Kopp Glass during EPA’s 2017 study. However, the data is limited. It is the opinion of the ACHD and the toxicologist it has retained, that there should be data from at least three months before the community health risk can be assessed. The Health Department will make the data public at that time. ACHD has also been in discussions with Kopp Glass to limit their emissions of metal hazardous air pollutants. Kopp Glass has cooperated in this process and has identified voluntary measures to reduce hazardous air pollutant emissions. During its discussions with Kopp Glass, ACHD also determined that it was subject to federal air quality regulations applicable to glass manufacturing facilities. A copy of the ACHD’s determination is available here. On July 27, 2020, the ACHD ordered Kopp Glass to submit a plan for compliance with the EPA regulations and to submit a Title V Permit application to the ACHD. A full copy of the order is available here. “We are pleased to see the health department embarking on this new air toxics study and we look forward to seeing the results once they are made public,” said GASP Executive Director Rachel Filippini. She continued: “GASP thanks the Allegheny County Health Department for not only initiating the air toxics monitoring study but for the wealth of information that is on its website. When we talk about transparency and regular, helpful communications to the public, this is the kind of thing we are talking about. I hope this is a sign of things to come from the new administration.” More information on the program can be found on the ACHD website. Editor’s Note: Kopp Glass Inc. on July 1 appealed an Allegheny County Health Department (ACHD) determination that one of its pot furnaces is subject to National Emissions Standards for Hazardous Air Pollutants for glass manufacturing area sources. #airquality #airqualitymonitoring #KoppGlass

When air quality was downright awful for more than a week during the festive season this past December, ACHD was quick to point out that a prolonged atmospheric inversion was the culprit. Technically speaking, an inversion will inhibit pollution from dispersing into the wider atmosphere, but make no mistake: An inversion will only concentrate pollutants, not create them. The polluters were the problem, not Mother Nature. Over the past month, ground-level ozone has exceeded federal health-based limits on several occasions in Allegheny County and in areas across southwestern Pennsylvania. Unlike this past winter though, inversions are not the cause. But that hasn’t kept ACHD from – yet again – placing a disproportionate share of the blame on Mother Nature. In emails sent out Monday and Tuesday addressing the recent spate of ozone issues, ACHD stated, “Ozone is a regional pollutant and is overwhelmingly weather dependent.” ACHD isn’t entirely wrong but there is a strongly misleading undercurrent to that statement. EPA’s Ground-level Ozone Basics website states: “(G)round level ozone is not emitted directly into the air but is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC). This happens when pollutants emitted by cars, power plants, industrial boilers, refineries, chemical plants, and other sources chemically react in the presence of sunlight.” To summarize: Ozone is a pollutant formed by other pollutants when they mix in the presence of sunlight. So, yes, sunlight is necessary and beyond the powers of county governments to control. But the other essential ingredients are pollutants that ACHD absolutely has the authority and an obligation to limit and regulate. To suggest that ground-level ozone is “overwhelmingly” dependent on weather implies that when the entire region sees hot, sunny days – as we have over the past month or so – the region as a whole should see high ozone readings. Thing is, that just isn’t reflected in the data from the past five weeks. We appreciate that ozone formation is complex and know ACHD will be deploying additional monitoring next year to research the issue further, but this is a problem now, and one that appears to require more than “closely monitoring this situation,” as ACHD promised to do in its recent emails. GASP is calling on ACHD to live up to a promise it made in January to examine and revise its regulations on so-called “Action Days.” When air quality is predicted to be poor, ACHD has very few and very weak regulations on the books that would require short-term reductions in or cessation of pollution-causing activities. What does it have? A robust list of steps residents can take to limit pollution-related activities. “It’s almost beyond the pale to ask residents – especially those who live in environmental justice communities polluted by industry – to significantly alter their daily routines on ‘action days’ while at the same time staying mum on what specific steps businesses need to take to do the same,” GASP Executive Director Rachel Filippini said. “It’s especially crass when you consider that curtailing production at major industrial facilities on ‘action days’ would reap far more air quality benefits than anything residents can do.” GASP believes it is imperative that ACHD’s Air Quality Program make good on a promise it first made way back in the 1970s and create not only procedures intended to stem industrial pollution during periods of bad weather but also every day through tighter coke oven regulations. ACHD and the state Department of Environmental Protection (DEP) must accept its duty to protect public health, even when Mother Nature complicates matters. Editor’s Note: Wondering where the air quality monitors are located throughout the region? Check out this map: #emissions #AlleghenyCountyHealthDepartment #ozoneexceedance #airqualitymonitor #Kittanning #ACHD #ozone #airquality

Allegheny County Health Department (ACHD) has assessed a $32,280 civil penalty against GenOn Power Midwest, LP, for 13 exceedances of a daily emissions limit at its Cheswick Generating Station in Springdale. The facility – the last remaining coal-fired electric generating plant in Allegheny County – is prohibited from emitting more than 3,176 pounds-per-hour of sulfur dioxide (SO2) on a daily average basis. But between Jan. 1, 2018, and March 31, 2019, GenOn exceeded its SO2 limit on 13 different days. Each of those instances is considered a separate violation of ACHD’s Air Pollution Control Regulations. While the facility’s total SO2 emissions for all of 2018 were well below its annual permitted limit, individual daily exceedances can be a cause for concern. Without an SO2 monitor near the facility, we can’t be certain if or to what extent the exceedances impacted air quality, but short-term exposures to SO2 can harm the human respiratory system and make breathing difficult. People with asthma, particularly children, are sensitive to the effects of SO2. SO2 and other sulfur oxides can also react with other compounds in the atmosphere to form fine particles that reduce visibility (haze) in parts of the United States. GenOn told ACHD that the exceedances were the result of a recycle pump failure on a scrubber after the pump was brought online following an extended time out of service. “The spray nozzle(s) associated with the pump became clogged with lime crystallization and failed to control excess emissions,” the enforcement order noted. Repairs to that nozzle were completed on April 24, 2019. ACHD indicated that GenOn did not initially disclose the violations in quarterly reports as required. The company also did not provide a required breakdown report detailing the pump failure that caused the SO2 exceedances as of July 30, 2020 – the date of the enforcement order. You can view the entire enforcement order on the ACHD website. #noticeofviolation #SO2 #CheswickPowerStation #emissionsviolations #emissions #GenOn #AlleghenyCountyHealthDepartment #ACHD

The Allegheny County Health Department (ACHD) on June 8 filed an enforcement order against Pittsburgh Cremation Services for failing to submit an application to renew its minor source operating permit. Minor source operating permits are valid for five years. Pittsburgh Cremation Services permit expired more than two years ago – May 30, 2018. The enforcement order also indicates that the company failed to submit required semi-annual reports. ACHD noted in the enforcement order that Pittsburgh Cremation Services was “reluctant, slow, took some corrective action but not all reasonable action.” Both are violations of Allegheny County’s Air Pollution Control Regulations. Pittsburgh Cremation Services had 30 days to pay the civil penalty, as well as the two most recent semi-annual reports. Within 60 days of the date of the order, the company must submit an application to renew its minor source operating permit. It was not immediately clear whether Pittsburgh Cremation Services paid the fine and reports – no further details were shared on the ACHD website. No associated appeal has been published on the ACHD appeals docket. Editor’s Note: ACHD on Aug. 13 posted information regarding several enforcement actions. One of them was related to emissions issues at U.S. Steel’s Edgar Thomson facility, which you can read about on our blog. #enforcementorder #USSteel #minorsourceoperatingpermit #airqualityregulations #emissions #AlleghenyCountyHealthDepartment #PittsburghCremationServices #EdgarThomsonPlant #ACHD #civilpenalty #airquality

According to the orders posted to the ACHD website Aug. 13, the companies violated Allegheny County’s Air Pollution Control Regulations by failing to submit required asbestos surveys and asbestos abatement demolition forms – documents that must be sent to ACHD 10 days prior to work commencing. For those who might be unfamiliar: Asbestos refers to a group of naturally occurring, fibrous minerals that can cause major breathing problems and even cancer. During demolition, old, brittle asbestos products can release tiny – even microscopic – fibers. These fibers are odorless and tasteless and can remain suspended in the air, entering your lungs when you inhale. Because of the significant health risk, ACHD regulates asbestos-handling activities. Allegheny County requires that all asbestos abatement contractors be licensed through ACHD.  All renovation and demolition work on buildings containing a certain amount of asbestos must follow ACHD rules and regulations (private homeowners, though, are exempt from these regulations when performing work on their own homes). ACHD issued enforcement orders against: Bristol Environmental on June 4, 2020 Urban Redevelopment Authority – Schaaf Excavating Contractors, Inc. on June 4, 2020 City of Pittsburgh – Schaaf Excavating Contractors, Inc. on June 4, 2020 Curtis Morehead – Jadell Minniefield Construction on June 4, 2020 PTV 1071 LLC, Lutterman Excavating, LLC on June 4, 2020 City of Pittsburgh, Deller Professional Services, Inc., June 30, 2020 ACHD ordered the companies to submit those documents or face a possible $25,000-a-day civil penalty. The companies had 30 days from the date of the enforcement orders to appeal. It was not immediately clear whether the companies complied – the ACHD website includes no further information on the orders. No associated appeals have been published on the ACHD appeals docket. In addition, ACHD issued an administrative order against CSI Construction, Inc., a licensed asbestos abatement contractor for prior compliance issues. The June 19 order details additional requirements the company must meet to keep its license: The company must have all pre-abatement setups inspected by ACHD prior to demolition. It must provide information to ACHD regarding the specific water source that will be used to adequately wet debris. The company must notify ACHD of the start date for demolition two days prior to its commencement. It must request a final clearance inspection from ACHD within 24 hours of demolition completion. #enforcementorder #airpollution #Asbestos #asbestosabatement #AlleghenyCountysAirPollutionControlRegulations #AlleghenyCountyHealthDepartment #ACHD

The Allegheny County Health Department (ACHD) on Aug. 11 issued a demand for stipulated penalties in the amount of $6,000 to ATI Flat Rolled Products and Harsco Corp. following residents’ complaints about dust on their cars that emanated from the nearby Natrona-based slag processing operations. The demand indicated that Brackenridge-based ATI (a specialty steel manufacturer) and Harsco (which processes slag from ATI) violated the county’s Air Pollution Control regulations four times between April 1, 2020 and June 30, 2020. According to ACHD, an investigation revealed that the dust observed on residents’ vehicles was consistent with slag fugitive emissions from Harsco/ATI operations. A previous investigation by the health department determined that the dust was primarily lime. Inhaling lime dust may lead to irritation of breathing passages, coughing and sneezing. How did ACHD come up with the $6,000 figure? A consent agreement between ACHD, ATI, and Harsco on Jan. 7, 2020 set a penalty of $1,500 per violation. ATI and Harsco have 30 days from the date of the demand to submit payment to ACHD. You can read more about the consent agreement – which required that the companies construct a building to enclose slag operations as well as pay a $107,000 civil penalty – on our blog. In a separate enforcement action, ACHD on July 30 assessed a $1,320 civil penalty against ATI for an opacity violation that occurred July 7, 2019 and was brought to light in a semi-annual report the company submitted to the department on Jan. 30, 2020. You can read the entire Notice of Violation here. Editor’s Note: The enforcement actions against ATI and Harsco were among many that ACHD published to its website on Aug. 13. The department also filed enforcement actions against U.S. Steel for visible emissions issues at its Edgar Thomson plant, as well as the GenOn plant in Springdale. There were also a number of asbestos-related actions, as well as one involving a local crematorium. #enforcementorder #ATI #stipulatedpenalties #Harsco #emissions #AlleghenyCountyHealthDepartment #EdgarThomsonPlant #ACHD

Media Contact: Amanda Gillooly GASP Communications Manager amanda@gasp-pgh.org/ 412-924-0604 FOR IMMEDIATE RELEASE GASP Delivers Widely-Supported Petition to ACHD Demanding Public Update on Emissions Issues at U.S. Steel Facility Signed by nearly 600 residents & 16 local organizations, it asks for an update on a compliance plan for the Edgar Thomson plant promised back in 2017. PITTSBURGH – The Group Against Smog and Pollution (GASP) today delivered a petition to the Allegheny County Health Department (ACHD) signed by nearly 600 people and 16 local organizations calling for a substantive public update regarding ongoing emissions events at U.S. Steel’s Edgar Thomson plant, as well as information on a compliance plan promised by the department and the U.S. Environmental Protection Agency following a 2017 joint notice of violation. The call to action comes in the wake of recent emissions events at the Braddock-based facility, as well as a June 1 enforcement order related to visible emissions violations there. GASP’s petition asks the health department for a substantive update on the long-promised compliance plan, which was supposed to detail what financial penalties would be assessed against U.S. Steel, as well as what equipment and operational upgrades would be required to bring Edgar Thomson back into compliance. “While ACHD acknowledged a reddish-brown plume emanating from the plant in June, telling the public it was investigating the incident and later revealing that a faulty valve was to blame, nothing further has been publicly stated about air quality compliance at Edgar Thomson,” GASP Executive Director Rachel Filippin said.  “What reassurance does the public have that this won’t happen again?” And enough is enough. “The public has waited long enough for an update on this public health issue, which impacts the day-to-day lives of our neighbors living in the communities surrounding the plant, those downwind of it, and everyone in between,” she said. “ACHD officials have repeatedly asked residents to be patient; to trust the process. But without transparency, there can be no trust. They must provide a detailed update as soon as possible.” North Braddock resident Edith Abeyta agreed. “We are told there needs to be more evidence. In addition to me and my neighbors there are hundreds of professionals and universities that are working on gathering enough proof – enough evidence – to back up the centuries-long lived experience that we are being harmed,” she said. “The sources of pollution are known. It is time for citizens to regain control of their air, water, time and health.” East Pittsburgh Borough Councilwoman Stacey Simon said the importance of a public update is paramount. “It’s a no-brainer to me: Breathing is essential to human life. The activities going on at the Edgar Thomson Works impact the quality of air that we breathe,” she said. “Knowledge is power, and we deserve to know more — so that we can do more — about the ongoing emissions issues at Edgar Thompson.” Lisa Graves Marcucci, a lifelong resident of the Mon Valley and Pennsylvania Community Outreach Coordinator at the Environmental Integrity Project said it’s long past time that U.S. Steel be held accountable for the ongoing emissions at Edgar Thomson. “We’ve waited too long for health to be the priority,” she said. “ The Allegheny County Health Department needs to stop coddling this company and get to work protecting public health and seeking the remedies outlined in the 2017 compliance plan.” Clean Air Council said the public deserves better. “ACHD owes it to the public to be transparent about its progress on a plan for ensuring U.S. Steel’s Edgar Thomson facility complies with the Clean Air Act,” said Joseph Otis Minott, Esq., Executive Director and Chief Counsel of Clean Air Council. “Allegheny County residents, especially those affected by air pollution from this facility, deserve nothing less.” The organizations that signed onto the petition were 3 Rivers Outdoor Co., Allegheny County Clean Air Now, Breath Project, Clean Air Council, Clean Water Action, East End Neighbors Concerned About Air Pollution, Environmental Integrity Project, Lawrenceville Clean Air Now, Nine Mile Run Watershed Association, North Braddock Residents for Our Future, Patagonia, PennEnvironment Research & Policy Center, PennFuture, Plant Five For Life, Rail Pollution Protection Pittsburgh and Sierra Club Pennsylvania Chapter. GASP  is a nonprofit citizens’ group in Southwestern PA working for a healthy, sustainable environment. Founded in 1969, GASP has been a diligent watchdog, educator, litigator, and policy-maker on environmental issues, with a focus on air quality in the Pittsburgh region. #EdgarThomson #noticeofviolation #USSteel #MonValley #LisaGravesMarcucci #emissions #AlleghenyCountyHealthDepartment #ACHD #airquality

A proposed consent decree that would settle a federal citizen’s suit filed in California regarding control emissions of volatile organic compounds from oil and gas industry sources could have an impact right here in Pennsylvania. That’s because the decree, published Aug. 21, would require the U.S. Environmental Protection Agency to find that Pennsylvania failed to submit proposed revisions to its State Implementation Plan (SIP) required by the Clean Air Act regarding the control of the volatile organic compounds (VOCs) emitted by the oil and gas industry in the Keystone State. Such a finding would be required by Oct. 30, 2020. But let’s back up a minute: Under section 110(c) of the Clean Air Act, an EPA finding that a state has failed to submit required revisions to its SIP, gives EPA two years to promulgate its own regulations and impose them on the state to ensure that requirements are being met, albeit belatedly. A state may, however, submit its own proposed SIP revisions to EPA during that two years, which EPA is free to approve, assuming the revisions meet the Clean Air Act’s requirements. The Clean Air Act requirements at issue arise out of a Control Techniques Guideline (CTG) for the Oil and Natural Gas Industry that EPA published in 2016 that provides guidance to the states as to what constitutes Reasonably Available Control Technology (RACT) for the control of VOC emissions. It should be noted that the Control Techniques Guideline is not itself a regulation. The Clean Air Act requires states with ozone nonattainment areas and those in the Ozone Transport Region (which includes Pennsylvania), to revise their SIPs to ensure sources covered by the Control Techniques Guideline implement RACT to control their VOC emissions. By way of background: Under the Clean Air Act, facilities covered by the 2016 Control Techniques Guideline in all areas of Pennsylvania (not just ozone nonattainment areas) are required to implement RACT to control their VOC emissions. The act gives the states two years to submit the required SIP revisions to EPA following the publication of a Control Techniques Guideline. It is important to note that states are not bound by a Control Techniques Guideline on how they implement RACT – they are free to come up with their own approaches to satisfy the Clean Air Act’s requirement. However, the emission limits contained in a Control Techniques Guideline establish a presumption for how the RACT requirement must be met. “A state that departs from the recommendations in a CTG must, therefore, establish to EPA’s satisfaction that the VOC controls in its proposed regulations satisfy the RACT requirement,” GASP’s senior attorney John Baillie explained. Pennsylvania failed to submit proposed revisions to its SIP that would require sources covered by the 2016 Oil and Gas Control Techniques Guideline to control their VOC emissions within two years of EPA’s publication of that Control Techniques Guideline. “In fact, Pennsylvania did not publish proposed rules to limit VOC emissions from sources covered by the 2016 Oil and Gas Control Techniques Guideline until earlier this summer,” Bailie said. “Because those proposed rules depart from the recommendations of the CTG in several respects, it is not certain that they meet the RACT requirement.” “Assuming that the Consent Decree is approved, we may find ourselves watching a race between the rule maker at two bureaucracies,” GASP Executive Director Rachel Filippini said. “What will happen first? Will Pennsylvania come up with its own regulations to control the oil and natural gas industry’s VOC emissions requiring the oil and natural gas industry to meet the RACT requirement, or will EPA write its own rules and impose them on industry sources in Pennsylvania?” A copy of the proposed consent decree is available by clicking through EPA’s website. EPA is accepting public comments on the proposed consent decree through Sept. 21. Editor’s Note: Stay tuned – we will keep you updated as this develops. #emissions #OilandGasIndustry #VOCs #volatileorganiccompounds

U.S. Steel’s Braddock-based Edgar Thomson Works is one of 11 integrated iron and steel manufacturing facilities in the country to be subject to amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAPs) that were finalized recently by the U.S. Environmental Protection Agency. These amendments didn’t just come out of the blue: Section 112 of the Clean Air Act directs the EPA to categorize sources of hazardous air pollutants (HAPs) and develop NESHAPs for them in order to minimize or eliminate emissions from sources in those categories. Here’s how it works procedurally: Within eight years of the promulgation of a NESHAP, EPA must review (and if necessary, revise) the standards to incorporate any new and improved “practices, processes, and control technologies” in the source category. The EPA must also determine whether the emissions allowed under the NESHAPs still pose an unacceptable risk to the public health or environment (after incorporating any new and improved practices, processes, or control technologies), and if they do, revise the standards to further limit emissions. The recent amendments, which are a result of such technology and residual risk review, will add limits on emissions of mercury from major sources in the iron- and steel-making industry, effective July 13, 2021. Airborne mercury causes harm to wildlife and to the human brain and nervous system, especially in fetuses and young children. Mercury can be present in emissions from the iron- and steel-making process when a facility charges the iron or steel it produces with automotive scrap if mercury-containing switches and devices have not been removed from it. The Edgar Thomson Works’ Title V Operating Permit currently does not include an emission limit for mercury but does prohibit the facility from using “#2 automotive scrap” (a term that does not appear to be defined by the permit) in any charge. The Edgar Thomson Works is otherwise allowed to use up to 40,000 pounds of “galvanized scrap” (also apparently undefined) per charge. “Going forward, the Edgar Thomson Works will either be subject to a stringent emission for mercury or need to certify that none of the automotive scrap it uses contains mercury,” GASP Senior Staff Attorney John Baillie explained. The recent amendments will also eliminate exemptions to the emission limits imposed by Subpart FFFFF for startup, shutdown, and malfunction events. This change was spurred by a 2008 federal appeals court decision – Sierra Club v. EPA – that determined such exemptions violate the Clean Air Act. “That means that startup, shutdown, and malfunction exemptions for sources in the category will cease to have effect beginning Jan. 11, 2021,” Baillie said. #airpollution #USSteel #JohnBaillie #EdgarThomsonWorks #emissions #CleanAirAct #TitleVPermit #NESHAPs #Mercury #EPA #airquality