Air Pollution Control Equipment Services, Emissions

CAAA Title III does concern power plants

Issue 3 and Volume 99.

ENVIRONMENTALLY SPEAKING

R.C. Rittenhouse,

Managing Editor

CAAA Title III does concern power plants

When the Environmental Protection Agency (EPA) declared combustion residue from power plants to be nonhazardous (which it is), a collective sigh of relief arose in the power generation industry. Then, when the attention turned to commercial boilers and their potential emissions of air toxics, it seemed, initially, that Title III of the Clean Air Act Amendments of 1990 (CAAA) might present little cause for concern at power plants. Not so.

That is why a planned session of POWER-GEN Americas ?94 (Dec., 1994, Orlando, Fla.) alerted attendees to the need for power plant staff members to carefully monitor coming air toxic emission requirements. Larry R. Alfred, Black & Veatch, brought the situation into focus during the conference session in his comprehensive status update of the Title III air toxics requirements for the power generation industry.

As he explained, Title III, Hazardous Air Pollutants, of the CAAA revised the Clean Air Act?s Section 112, which was the federal hazardous air pollutant (HAP) emissions program. Section 112(b) of the CAAA contains the now familiar list of 189 chemicals (HAPs) that could be hazardous to human health. Under this title, EPA also has listed 174 Omajor sourceO and Oarea sourceO categories for issuing air toxics emissions standards. Further, EPA must promulgate National Emission Standards for Hazardous Air Pollutants (NESHAPS) under each source category. These standards will require implementation of maximum control technology (MACT).

To review: Title I of the CAAA controls of criteria pollutant emissions to achieve and maintain National Ambient Air Quality Standards (NAAQS); Title IV reduces pollutant emissions related to acid deposition and Title V establishes state administered operating permits for air pollution sources violations. Title III requires HAPs to be regulated by the EPA and by states through Title V requirements, which now are under development. Remaining titles have little to do with power plants.

Putting it all together

How does it all fit? The importance of monitoring Title III-related activity seemed even more pressing as expressed in a letter from Gale F. Hoffnagle, TRC Environmental Corp. vice president and technical director. Here is his view of why power plant staff members need to become totally familiar with the interaction of the various CAAA titles: OElectric utilities have to pay attention to Title III even though Title IV?s Oaffected sources? (including power plants) are not currently included as a source category under Title III.O Each source category is required to have a maximum achievable control technology standard to reduce emissions of hazardous air pollutants. EPA has designated industrial boilers and institutional/commercial boilers as two separate source categories that are scheduled for promulgation of MACT standards in the year 2000.

EPA was required to conduct a study of the affected sources to determine if their HAP emissions were sufficient to require listing as a source category. Although this study has been delayed, EPA expects to report to Congress in November 1995, at which time EPA could propose that affected sources be listed as a source category. In addition, affected sources are not subject to the need for ONotice of MACT ReviewO 112(g) construction permits for new, modified or reconstructed sources. This is crucial because the 112(g) permitting requirements go into effect as soon as each state is granted Title V operating permit approval. Electric utility sources, which are not affected sources, are not exempt from these provisions.

Electric utilities also are not exempt from the provisions of section 112(r), accidental releases. If a utility stores, or otherwise has on-site, more than the threshold quantity of an extremely hazardous substance (EHS) as listed in section 112(r) (ammonia, sulfuric acid and chlorine are common utility EHSs) then a risk management plan will be required for each EHS. The Title V operating permit requirements do not exempt affected sources from either obtaining permits or counting their Title III HAPS. Electric utilities must inventory their HAP emissions even if not subject to a Title III rule. HAPs are to be counted in determining major source status.

Potential-to-emit 10 tons per year of any one HAP or 25 tons per year of the combination of all HAPS would make a facility subject to a Title V permit. When determining major source size, all emissions (stack and fugitive) across the entire contiguous or adjacent property under common ownership and control must be counted. EPA recently interpreted this as being regardless of SIC code (i.gif. a mine mouth plant would have to count HAP from the mine and the power plant). One significant, unresolved issue is the emission rate of radioactive materials that would qualify as a major source of HAPs. EPA has yet to set the major source threshold for radioactive emissions. Note: It will not be 10 ton/yr!

Although affected sources currently are not subject to Title III, all utility sources must quantify their HAP emissions for their Title V permits. This is a serious undertaking and could be the subject of much discussion during any public hearing on a power plant?s Title V operating permit. OQuantification of the potential-to-emit of all metals (including mercury and lead), all the organics (including benzene) and exotics (including dioxin, PAHs and radioactivity), all have the ability to excite or incite the public over a power plant?s permit application,O Hoffnagle concluded.

For clarification

If the Title III situation is as confusing as it sounds, write to Laura C. Ariane, Conference Manager, POWER-GEN ?93, 3050 Post Oak Blvd., Suite 205, Houston, Texas 77056-6524 for information on obtaining a copy of the paper by Larry R. Alfred. Gale F. Hoffnagle can be reached by writing to him at TRC Environmental Corp., 5 Waterside Crossing, Windsor, Conn. 06095. Other sources for details include the Environmental Protection Agency, 401 M Street S.W., Washington, D.C. 20460; and Babu Nott, Electric Power Research Institute project manager, 3412 Hillview Ave., P.O. Box 10412, Palo Alto, Calif. 94303-0813. END