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Annual Site Environmental Report for 1999
Clean Air Act Amendments of 1990
The CAA Amendments of 1990 are
divided into six major titles. The two titles that
could affect DOE activities at the Paducah Site
are: 1) Title III, Hazardous Air Pollutants, and 2)
Title VI, Stratospheric Ozone Protection.
Title III, Hazardous Air Pollutants
Under Section 112, requirements shifted
from a pollutant-by-pollutant, health-based
regulatory approach to regUlation of categories
of sources using technology-based standards.
Examples of hazardous air pollutants that must
be regulated by the EPA include volatile organic
compounds (VOCs) such as benzene, and
metals such as chromium, cadmium, and
manganese. The following summarizes key
aspects of this legislation.
A. Pollutants and Sources Subject to
Regulation
by virtue of its individual or total hazardous air
pollutant emissions and is not currently
regulated under Title III.
B. Control of Accidental Releases
Title III requires EPA to promulgate
regulations to control and prevent accidental
releases of regulated hazardous pollutants and
extremely hazardous substances listed by EPA.
Owners and operators of facilities where such
substances are present in more than a threshold
quantity were required to prepare risk
management plans by June 21, 1999, for each
listed sllbstance used at the facility. The Paducah
Site does not store or process any of the
hazardous pollutants above threshold quantities
and does not require a risk management plan. If
DOE decides to construct and operate the Vortec
project, it would exceed the threshold of to,OOO
pounds of propane and, consequently, would
require a risk management plan.
Title VI, Stratospheric Ozone Protection·
The CAA amendments completely
overhauled the regulatory approach used for air
toxies. Under the new approach; 189 substances
are listed by Congress for regulation. Substances
can be added to or deleted from the list after rule
making, but EPA need not take any action· with
respect to these 189 substances.
Within one year of enactment, EPA was
required to publish a list of all major source
categories and subcategories of the listed
hazardous air pollutants, such as oil refineries
and chemicai' plants. EPA issued'a list of source
categories for regulation under Section 112 in
July 1992. Any.stationary source emitting more
than mtons/year of any of the listed substances
or 25 tons/year of any combination of the
substances is considered a major source and is
subject to regulation. EPA must examine other
sources for regulation under an "area source"
program. The Paducah Site is not a major source
Title VI of the 1990 amendments
incorporates stratospheric ozone protection by
restricting the production and consumption of
chlorofluorocarbons, methyl chlorofonn, halons,
carbon tetrachloride, and hydrochlorofluorocarbons.
Halon, methyl chloroform,
chlorofluorocarbons, and carbon tetrachloride
have been phased out in DOE operations. The
phaseout of hydrochlorofluorocarbons is to be
accomplished over a longer period, stretching
out to 2020-2040. The 1990 amendments also
require that production and consumption of
hydrobromofluorocarbons be phased out
beginning in 1996 and that methyl bromide be
added to .the list of controlled substances.
DOE only has refrigeration units that
contain less than 50 pounds of listed substances;
therefore, the only part of this regulation that
applies to the Paducah Site is the requirement to
control refrigerants from leaking systems and
Environmental Compliance
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