Chapter 3: What Changes Were Implemented at Edgar Thomson Thanks to the Consent Decree
- Group Against Smog & Pollution
- Jan 22, 2025
- 9 min read
Updated: 2 hours ago
Editor’s Note: This is the third of a four-part series examining the years-long fight to get U.S. Steel’s Edgar Thomson facility in North Braddock in compliance with a host of air quality rules and regulations. In part one, GASP explored the spate of emissions violations and compliance struggles that led to a joint enforcement action from EPA and ACHD in 2017 and ultimately a controversial settlement decree.
Before we get too far into the weeds about consent-decree related maintenance, equipment and operational changes at U.S. Steel’s Edgar Thomson Works, we think it’s important we all have a baseline understanding of how the facility runs.
Here’s the short version: U.S. Steel’s Mon Valley Works is what is known as an integrated steel-making operation. That means U.S. Steel starts with raw materials – iron ore, coal, etc. – and produces finished steel.
The Edgar Thomson facility makes molten iron (or pig iron) in its blast furnaces using coke from Clairton, iron ore, and other materials. Within the blast furnace casthouses, the furnaces are tapped and the pig iron is collected in rail cars (called torpedo cars) for transfer. A molten sulfurous metallic waste product of the blast furnace is slag, which is diverted into open pits to cool before processing.
The facility turns iron into steel by way of the basic oxygen process (BOP) in a part of the mill aptly named the BOP shop. Molten steel is poured into a continuous caster that creates steel slabs, which are then shipped by rail to the Irvin Works for finishing.
GASP staff put together these visuals of the facility so you can reference it as we proceed:
The actions the consent decree required U.S. Steel to take generally fall into four broad categories, with specific deadlines set for each action item:
record-keeping and reporting,
emissions reductions from specific processes,
enhanced emissions monitoring, and
enhanced equipment maintenance.
Now for the big question: Has U.S. Steel met the obligations set forth in the deal? Let’s get into the nitty gritty…
What About Those Record-keeping and Reporting Requirements
After a review of the documents obtained from ACHD through a public records request, GASP can report that yes, so far U.S. Steel has met the deadlines associated with its semi-annual and other required reports.
The semi-annual reports have been submitted on or before the Feb. 28 and June 30 deadlines set forth in the agreement. These reports chronicle U.S. Steel’s deliverables for EPA and ACHD and provides a solid timeline for the various projects - many of which are YEARS in the making.
There is a plethora of information in these reports - here’s the last one U.S. Steel submitted to give an idea of its contents and format:
You can read all the semiannual reports below. The July-December 2025 report is due to ACHD and EPA Feb. 28, 2026. GASP intends to make a public records request for this and all subsequent reports required by the decree.
Semiannual Reports
What About Those Training Requirements?
Documents show that U.S. Steel began developing the required training material in the first half of 2023 and that training of “appropriate personnel” was completed by year’s end.
According to U.S. Steel’s February 2024 semi-annual report, 314 employees were provided this training.
“Topics will include discussion of applicable requirements, potential emissions sources, and activities and available tools to address those sources and activities,” the company wrote in its August 2024 semi-annual report.
About The Required H2S Suppression System
Feb. 14, 2023 - U.S. Steel completed the installation of a temporary system for the feeding of hydrogen peroxide into the slag pit quench water spray system.
May 15, 2023 - U.S. Steel submitted to EPA for approval a proposed written procedure for its system for feeding hydrogen peroxide into the slag pit quench water spray system.
GASP’s public records request revealed no further details about the project. Subsequent semi-annual reports indicate that U.S. Steel is still awaiting that EPA approval.
About The Blast Furnace Casthouse Emissions Control System
Here are the key dates associated with the Blast Furnace Casthouse Emissions Control Systems:
Jan. 16, 2023: U.S. Steel submitted its casthouse baghouse system study plan to ACHD and EPA.
March 6, 2023: U.S. Steel re-submitted its casthouse baghouse system study plan per an ACHD request for clarification.
April 18, 2023: EPA provides U.S. Steel written approval of the casthouse baghouse study plan after consultation with ACHD.
Oct. 23, 2023: U.S. Steel submitted its Blast Furnace Casthouse Emissions Control System evaluation report - along with its recommendations and responses - for approval.
You can read the entire casthouse baghouse system study here - and we recommend you take a gander. It includes robust - albeit extremely technical and engineering-heavy - information and visuals. But here are two main takeaways:
#1: The evaluation showed that U. S. Steel was able to satisfactorily maintain compliance with all applicable air quality regulations. The existing casthouse baghouse system and trough hoods are generally effective at capturing emissions from the taphole and iron trough.
#2 Visible Emissions Observations (VEOs) indicated that casting operations on the casthouse floor, outside of the existing baghouse control area (such as the iron runner, spouts, and ladle car transfer areas), have a greater impact on opacity at the casthouse roof monitor than the taphole/trough area.
However, deficiencies in the casthouse baghouse system were identified and a slate of recommendations for remedying them were issued.
Here are the short-term recommendations, which the contractor noted are primarily for optimization and will not significantly change VEOs at the roof monitor. They include:
Eliminate ingress air by increasing the inspection regime and conducting maintenance/repairs to the ductwork and access ports.
Update damper logic to better distribute flow between the two casthouses
Increase I.D. fan speed.
Optimize flame suppression system by increasing lance size/gas flow and conducting a study for a dedicated gas line.
Improve torpedo ladle car positioning through better training/communication and a study on the viability of an automated system.
Here are the intermediate-term recommendations that focused on optimizing the existing system and minimizing VEOs. They include:
Installation of a dedicated gas line to each casthouse from the compressor station based on the short-term study.
Automation of the torpedo ladle car positioning based on the short-term study.
Improve air curtain operation by implementing modifications to reposition or enhance air flow.
The redesign and replacement of the fan inlet plenum if extensive repairs are necessary.
However, it’s the long-term recommendations that most piqued our interest here at GASP.
The report stresses that these recommendations would be implemented, “If, after all short- and intermediate-term improvements, USS is still unable to maintain compliance, four long-term options were evaluated for controlling casthouse floor emissions. These would require a new or significantly expanded baghouse system.”
About the Bop Shop Roof Ventilation & Scrubber Systems
Here are the key dates associated with those systems:
Jan. 16, 2023 - U.S. Steel began its pre-study visible emissions observations for Edgar Thomson’s blast furnace casthouses and BOB Shop emissions modules (for its roof monitors and scrubber stacks).
Feb. 14, 2023 - U.S. Steel submitted study plans to ACHD and EPA for its BOP Shop Roof Ventilation and BOP Shop Scrubber.
Oct. 25, 2023 - U.S. Steel self-reported in an annual report an instance of noncompliance with VEO observations. The report stated, “Due to a misunderstanding and training miscommunication, the contractor VEO reader failed to continue conducting Method 9 observations when a deviation from an applicable opacity was observed…The contractor has since been retrained on the requirements of taking observations in accordance with the consent decree.”
April 5, 2024 - U.S. Steel experiences a deviation of its opacity standards during its VEO observations. The company noted there was a maximum opacity of 25 percent was experienced from Blast Furnace 1 during a 60-minute period. In an annual report the company provided this explanation, “There was high moisture in the trough due to heavy rainfall. The employees were retrained on reducing moisture in the trough during heavy rainfall.”
The study plans can be read in full here.
About the SO2 CEMS Monitoring Plan for Edgar Thomson’s Riley Boilers
March 14 - U.S. Steel submitted its SO2 CEMS monitoring plan for Edgar Thomson’s Riley Boilers to DEP and was working with the department on requested revisions.
April 4 - DEP approved U.S. Steel’s SO2 CEMS Monitoring Plan for Edgar Thomson’s Riley Boilers.
July 4 - U.S. Steel completes phase 2 testing for its SO2 CEMS Monitoring Plan for ET’s Rile Boilers and sends a report to DEP verifying compliance with all regulatory requirements.
Aug. 23 - DEP approves the certification of U.S. Steel’s test results for its SO2 CEMS Monitoring Plan for ET’s Riley Boilers. Meanwhile, the company noted in an annual report that it was working to submit sample reports to the department for approval of phase 3.
Documents GASP obtained through a public records request provided no additional details about the status of phase 3. GASP submitted a subsequent request for additional documentation and will provide an update when further information is available.
What About Those Enhanced Monitoring Requirements?
Our documents review revealed that U.S. Steel appears to have fulfilled the requirements related to the installation and maintenance of the seven video cameras to monitor problematic sources of visible emissions (reminder that those include the blast furnace stove stacks, casthouse roof monitors and baghouse, BOP shop roof monitor and scrubber stacks, and two staging areas for torpedo cars).
U.S. Steel’s Aug. 30, 2023, semi-annual report indicates that the cameras were installed by the June 14, 2023. deadline. Incorporation of these cameras into the facility's procedures and operator training was completed as expected by Oct. 12, 2023, according to the company’s Feb. 27, 2024, report.
Happening In the Meantime
When it comes to air quality issues, nothing happens in a vacuum. As U.S. Steel and regulators worked their way through the conditions set in the consent decree, it’s important to note that a lot was happening in the background regarding Edgar Thomson and emissions issues there.
For one, ACHD published a revised Title V operating permit the Edgar Thomson facility Aug. 23, 2024, which kicked off a 30-day public comment period.
This was necessary because both the EPA and U.S. Steel appealed the initial permit, which led to changes subsequent enough that it required a second public comment period to allow stakeholders to address them.
Why is that important? It’s important because some of the Title V limits that U.S. Steel appealed also impact the deliverables for the consent decree.
Second, it’s crucial to note that the consent decree did not stop U.S. Steel from racking up air quality violations.
On Aug. 2024, for example, ACHD issued an enforcement order to U.S. Steel for emissions violations related to carbon monoxide and assessed a $12,300 civil penalty. ACHD noted that the Edgar Thomson plant was exceeding both the hourly limits for carbon monoxide emissions as well as its annual limit. According to the enforcement order:
“The short-term hourly emission limitation…for CO is 2,575.44 lb./hr. On January 25, 2024, ET performed compliance testing on the BOP Primary Collection Scrubber System. On March 28, 2024, ET submitted the compliance test report. The three runs showed 4,599 lb./hr., 2,714 lb./hr. and 2,723 lb./hr. per hour. The average test results for the BOP Primary Collection Scrubber System were 3,346 lb./hr., exceeding the permit limit of 2,575.44 lb./hr.”
It also didn’t stop high-profile equipment breakdowns.
On Feb. 23, 2025, U.S. Steel experienced a breakdown at the Edgar Thomson facility that resulted in damage to the building.
Two days later, ACHD issued a press release relating to the weekend breakdown, providing this information from U.S. Steel:
US Steel has tarped the hole until a permanent repair can be made and slowed down production. For more information regarding issues within the Edgar Thomson facility reach out to U.S. Steel.
The required pollution monitors were not damaged by this issue. The Allegheny County Health Department (ACHD) will continue to investigate the breakdown.
That same day - Feb. 25, 2025 - GASP staff contacted ACHD’s public information officer to inquire whether the breakdown could be related to sky-high concentrations of hydrogen suffice (H2S) that exceeded the state standard during the same time period. ACHD responded immediately via email, stating: “The cause of the H2S values are under investigation and we cannot provide any further comments at this time.”
In a subsequent email sent the same afternoon, ACHD announced sulfur dioxide exceedances at the Braddock air monitoring site near the Edgar Thomson facility.
The consent decree with regulators wasn’t the only legal action related to Edgar Thomson: U.S. Steel also settled a class-action lawsuit filed in 2022 regarding dust and other noxious emissions from its Edgar Thomson facility in North Braddock, agreeing to pay a $6.1 million civil penalty.
Of that money:
$1.5 million will be paid out to those who opted into the legal action.
$2.25 million was earmarked for the construction of two-wheel wash stations to clean vehicles exiting the facility.
$1.6 million was designated for paving the onsite street informally known as Burma Road
$740,000 would be used to purchase to street sweepers for use at - and in the vicinity of - the Edgar Thomson facility
Finally, U.S. Steel in September 2025 announced it approved its next phase of capital investment plans, which included the construction of a $100 million slag recycling facility at the Edgar Thomson Works.
While the company took a public relations lap lauding the investment, we feel it necessary to point out that the consent decree required U.S. Steel to reduce emissions from its slag pit operations.
Next up: Chapter 4, where we explore what's next and why we need YOU.
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