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. Earlier this week, we told you about the latest enforcement action against U.S. Steel for air quality violations at its Clairton Coke Works facility. Here are the other new cases uploaded to the docket:
The Allegheny County Health Department (ACHD) issued a $3,410 civil penalty against Neville Island-based INEOS Composites for failing to report an equipment breakdown and record-keeping issues that stem from an April 2022 facility inspection.
According to the enforcement action, an ACHD inspector noted INEOS did not report a temperature exceedance for Maleic Anhydride Storage Tank F-4602 within 60 minutes as required. The company also failed to submit a written report within seven days, as its permit requires.
“Plant personnel stated that the incident was due to a steam bypass valve being open that was supposed to be closed,” the document states. “They stated that the previous day, April 13, 2022, they had observed the temperature at 72° C, or 162° F. Plant personnel stated their belief that they were not required to report the incident as a breakdown because it was due to human error.”
The June 21 enforcement action notes that “to date, ACHD has not received a written report” addressing the exceedance.”
ACHD further indicated that INEOS was unable to provide the inspector with data of daily plant production and the amount of each monomer used for September 2020 and September 2021 - record-keeping that’s also required by its permit.
“Plant personnel indicated that they were not keeping and did not believe they were required to keep daily production or monomer usage records,” the document notes.
In addition to the civil penalty, ACHD ordered the company to report all breakdowns caused by human error as well as keep daily production or monomer usage records within 30 days and report that usage in the next two semi-annual reports due July 31 and Feb. 1, 2024.
You can read the entire enforcement order here.
ACHD, ALCOSAN Enter Consent Agreement Over Agency Exceeding Emissions Limits
ACHD and ALCOSAN have entered into a consent decree because the authority exceeded emissions limits of harmful air pollutants such as lead and hydrogen chloride - exceedances for which a nearly $6,000 civil penalty was assessed.
At this point, we need to stop to understand a little bit of background: ALCOSAN operates a publicly owned treatment works facility located at 3300 Preble Ave. in Pittsburgh that serves 83 local municipalities and processes more than 200 million gallons of wastewater per day on average.
ALCOSAN is a minor source of all criteria pollutants and hazardous air pollutants (HAPs), operating two sewage sludge incineration units that must meet specified emission limitations for cadmium, carbon monoxide, dioxins/furans, hydrogen chloride, lead, mercury, nitrogen oxides, particulate matter, and visible emissions.
That operating permit requires periodic stack tests to demonstrate compliance with these emission limits on an annual basis. It also allows stack tests for a given pollutant to be performed less often when two prior consecutive stack test results for a given pollutant are at or below 75% of the respective emission limit and there are no changes in operation that could increase emissions.
Now back to that enforcement action: It states that from Aug. 25- 27, 2020, ALCOSAN conducted a stack test on one of its SSI units, known as FBI-2, for all the emissions limits we mentioned earlier. On August 28, 2020 - and prior to receiving the August 2020 stack test results - ALCOSAN took FBI-2 out of service.
The results of this stack test, which ALCOSAN received and submitted to the ACHD in October 2020, showed that the measured emissions of hydrogen chloride and lead exceeded the emission limits.
Subsequent stack tests also showed that the measured emissions of cadmium and lead exceeded the emission limits set forth in its permit. Regarding hydrogen chloride, ACHD examined the June 2021 stack test results and later determined that the stack test results for hydrogen chloride were incomplete and/or invalid - FBI-2 was active in 2021 only long enough to conduct stack testing.
ACHD ultimately issued a Notice of Violation against ALCOSAN in December 2021. In the months that followed, ALCOSAN worked with ACHD to conduct testing and sampling. In March 2022, ALCOSAN stack tests demonstrated compliance with emissions limits.
As a result, ACHD issued ALCOSAN its operating permit on Sept. 21, 2022.
You can read the entire consent decree here.