GASP Comments on ACHD Permit # 0679-I001
These comments are regarding the application by PDG Land Development for an Air Quality Permit from the Allegheny County Health Department, Permit #0679-I001.
March 4, 2003
My name is Rachel Filippini, and I am the Program Coordinator with the Group Against Smog & Pollution (GASP).
According to the PA Department of Environmental Protection, Allegheny County has the highest level of PM2.5 in the entire state. We should be extremely cautious about granting a permit to a facility or activity that will increase our overall exposure to more PM2.5, since it is highly likely the county will fall into nonattainment for PM2.5. This project will create new emissions, and although the estimated emissions may be within the regulations, the cumulative impact on the county as a whole will likely increase, especially for particulates. The impact on those who live in the vicinity of the project will be significant.
The Allegheny County Health Department (ACHD) declares that pollution prevention is the preferred strategy, over pollution control for reducing risk to our precious air resources. We find that there are few methods for fugitive dust control in the installation permit. GASP would like to see a more aggressive approach in place, including but not limited to the use of enclosing or covering operations, planting vegetative cover, covering conveyor systems, paving all roadways and parking lots, and using industrial windfences where applicable. In all cases, dust control efforts should be monitored on a regular basis to ensure that the measures taken are adequately controlling fugitive dust. Dust fall standards should be reported more frequently than once every six months, the community should know sooner if there is a problem, and of course the problem can then be corrected sooner. In general, all reporting should occur at least quarterly. This is a dynamic site with ongoing changes.
Fugitive dust is a health concern. Fugitive dust is comprised of fine particulate material that irritates eyes and nasal tissue and seriously impacts the respiratory system. The tiniest parts of fugitive dust may reach the working surfaces (alveoli) of the lungs and reduce lung capacity. Fugitive dust also inhibits normal plant growth and development.
Another pollution prevention strategy is for the coal crusher generator to only burn ultra low sulfur diesel fuel, as well as being retrofit with the latest technology to reduce particulate matter, carbon monoxide, hydrocarbon and toxic hydrocarbon emissions. The most up to date compliant engines/equipment for the task both of rock and coal crushing should be required and a schedule of maintenance with specific definition of the maintenance activities should be required as well.
The permit does not take into account the emissions from the large number of heavy duty diesel trucks that will traverse the site. Almost a year ago, Trans Associates (TA) prepared a Transportation Plan for the removal of coal from the site. At that time the projected coal removal from the site, and therefore trips generated by trucks for the removal of coal was estimated to start at 44 truck trips per day in the first eight months, increase to 68 truck trips per day in the next four months, and thereafter increase to 88 truck trips per day. It is unclear if these numbers are still accurate, since the permit doesn’t include them, and doesn’t calculate from them the potential emissions of PM, PM2.5, PM10, and NOx, which could be considerable. The Environmental Protection Agency lists diesel exhaust as a mobile source air toxic due to the cancer and noncancer health effects associated with exposure to whole diesel exhaust. There is no accounting for any specific toxic emissions from the trucks or equipment. I believe it is also fair to say that the trucks are not just a mobile source of emissions, but also that they will be emitting while at the site. GASP would recommend again that ultra low sulfur diesel fuel be used for these trucks along with employing retrofit technology to reduce emissions.
ACHD requires the chemical/water spraying of facility roadways. The permit should list which chemicals and in what amounts would be used for this activity? What is the plan for dust suppression when the ambient temperature is below 32 degrees Fahrenheit? Since the main method of fugitive dust control is water spray, the permit should tell us where the water is coming from to perform this vital activity.
The crushed coal and rock stockpiles should be designated away from homes. Where there will be dropping of crushed coal and rock onto these drop piles, the drop distance should be kept to a minimum.
Lastly, it would be helpful to have a facility site plan map that records all paved and unpaved haul roads, crushed coal and crushed rock stockpiles, parking lots, location of the coal crusher generator, stone crushing process, and the coal processing plant; showing the proximity of these to nearby residents. The facility site plan map should indicate prevailing wind direction, and areas where dust control will take place.
I hope these comments and the comments of other concerned citizens and groups will play a part in your decision to grant the installation permit.