Chapter 2: Consent Decree Mandates Massive Changes at Edgar Thomson

Editor’s Note: This is the second 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. Part one can be read here.

After YEARS of radio silence from air quality regulators - and amid mounting public pressure from GASP for action and transparency - the Mon Valley was rocked by the May 2022 announcement that local and federal authorities had reached a deal with U.S. Steel regarding ongoing emissions violations at the Edgar Thomson Works. 

Six months later, a federal district court judge approved the long-awaited consent decree, which imposed a $1.5 million fine on U.S. Steel and mandated a slate of improvements at the North Braddock facility. 

The goal? To ensure Edgar Thomson got into - and maintained - compliance with all applicable air quality laws and regulations.  

About That Fine 

Half the fine - $750,000 - was funneled to the Allegheny County Department of Economic Development, which ACHD has approved to manage a fund to bankroll community environmental projects. 

The other half of the fine was earmarked to fund “the Allegheny County Department of Economic Development in support of the creation of a multimodal connection that links the Great Allegheny Passage (GAP) in Rankin Borough to the Westmoreland Heritage Trail (WHT) in Trafford Borough through the Turtle Creek Valley.” More on that here. 

The actions mandated by the consent decree can be sorted into three broad categories: emissions reductions from specific processes, enhanced emissions monitoring, and enhanced equipment maintenance complete with stringent deadlines and robust reporting requirements for U.S. Steel. 

Emissions Reduction Mandates

First, let’s talk emissions reductions: U.S. Steel was required to begin “feeding an oxidizing chemical additive or additives . . . into the slag pit quench water spray system, to enhance suppression of H2S emissions.” 

The company was also required to submit to the EPA and ACHD written procedures detailing how it will continue to reduce emissions from slag pit operations. 

U.S. Steel was also ordered to obtain an independent engineering evaluation to identify potential emissions reductions from the blast furnaces’ casthouse baghouse system, the BOP shop roof ventilation, and the BOP shop scrubber system.  

Independent third-party contractors were hired to conduct studies of all three systems. And for all three studies, those contractors were required to submit detailed plans for conducting those studies - and EPA and ACHD were required to approve all of it. 

Monitoring Requirements

Next, let’s talk about what the consent decree required by way of monitoring.  

First, U.S. Steel was required to permanently install and maintain no fewer than seven video cameras aimed at problematic sources of visible emissions including the blast furnace stove stacks, casthouse roof monitors and baghouse, BOP shop roof monitor and scrubber stacks, and two staging areas for torpedo cars. 

It bears noting: The decree states this equipment will be used to keep a better eye on potential emissions sources so U.S. Steel can take “corrective actions to minimize or eliminate any such emissions as expeditiously as possible.” They may NOT be used to determine compliance. 

In addition to the camera system, U.S. Steel also needed to hire a third-party observer – trained and certified in accordance with EPA Method 9 – to begin conducting visible emissions readings covering the casthouse roof monitors, BOP shop roof monitor, and BOP shop scrubber stacks twice a week when the equipment was operating. 

However, the decree requires Method 9 inspection frequency to increase to four days per week. But that extra monitoring has an end date: It will end after four consecutive months of 100 percent compliance or 12 months from the start of the more frequent inspections (whichever is sooner). 

These monitoring requirements are coupled with various reporting deadlines, as well.  

Finally, the agreement required U.S. Steel submit a monitoring plan to install a continuous SO2 monitor for Edgar Thomson’s Riley boilers. For the uninitiated: These boilers burn blast furnace gas, coke oven gas, and natural gas to generate steam, heat, and electricity for the plant. 

Facility Maintenance Upgrades

Next up: Let’s talk about what the consent decree had to say about facility maintenance. 

First, it required U.S. Steel to hire a third-party contractor to conduct a maintenance practices audit analyzing control operations and maintenance practices for the casthouse baghouse, the BOP shop fugitive emissions baghouse, the BOP shop mixer baghouse, the BOP shop LMF baghouse, the BOP shop primary emissions system/BOP shop scrubber, and the slag pits. 

The report was to detail: 

• audit findings, including the basis for each finding and each area of concern related to the adequacy of Edgar Thomson’s operations and maintenance plan for ensuring current and continued future functioning of emissions controls and compliance with applicable emission limitations 

• information about whether requirements, targets, objectives, or other benchmarks are being achieved; whether there are examples of noncompliance with the operations and maintenance plan; and “recommendations for resolving areas of concern or otherwise achieving compliance with the operations and maintenance.” 

After receiving the auditor’s report, U.S. Steel was required to submit that information to the EPA and ACHD along with a proposal for implementing recommendations. 

But the audits don’t stop there: In addition to the third-party audit, the agreement requires U.S. Steel to undergo self-audits every 12 months and submit for approval plans to EPA and ACHD detailing everything from obstacles encountered to the adequacy of the operations and maintenance plan to whether required objectives and benchmarks are being met. 

Reporting Requirements

Last but not least, the consent decree requires U.S. Steel to submit to EPA and ACHD semi-annual reports detailing everything from the progress made on required upgrades and training to problems encountered and changes made to the facility’s operations or maintenance plans. 

Those reports must be submitted by Feb. 28 and Aug. 31 each year. 

Did U.S. Steel meet the deadlines set forth in the consent decree? What operational and maintenance changes have been made since the 2022 agreement was inked? What has the fine money funded and what’s the status of that multi-modal trail collection? 

We explore this and more in the third installment in our series, which you can read here.