On July 31 and Aug. 1, the Environmental Protection Agency (EPA) held listening sessions in Pittsburgh. The officials took comments from the public on the EPA’s proposed Clean Power Plan, which will regulate carbon dioxide emissions from electrical generating units. While the plan is not perfect, GASP supports it in essence. The proposal, when fully enacted by 2030, will prevent thousands of premature deaths and up to 150,000 asthma attacks in children per year, slow down global warming, lessen the cost of electricity, and make our nation a leader in the next generation of clean technology. Learn more by visiting EPA’s web pages on the issue, and read our comments below. You can also submit your own comments, directly from EPA’s web site, but must do so by Oct. 16. August 1, 2014 Via Electronic Submission Re: Comments on Docket ID No. EPA-HQ-OAR-2013-0602 Dear Environmental Protection Agency: The Group Against Smog and Pollution, also known as GASP, submits these comments in support of the Clean Power Plan. While the details of the plan are rather complicated, the big picture is simple to comprehend. Global warming threatens our nation, and CO2 causes much of the warming. The EPA has the authority and the mandate to regulate CO2, and this proposal does just that. Many commenters have praised the reduction of CO2 and mitigating global warming, and we applaud the EPA for taking this strong step, by addressing emissions from our nation’s largest single source of CO2. This action will be a model to countries around the world and we should take pride in leading the fight. But as a nonprofit based in southwestern Pennsylvania that’s also fought for 45 years to reduce emissions that have short-term, or even immediately toxic effects, such as particulate matter, sulfur dioxide, nitrogen oxides, air toxics, and other pollutants, we are especially excited to see the co-benefits of reducing these pollutants that this rule will provide. Pittsburgh is known for its smoky past. Many outsiders still have that image of the city. While Pittsburgh no longer turns on street lights at noon to see through the smoke, we do suffer from high levels of ozone and fine particulate matter. Perhaps “The Blue Ozone Haze City” or “The City With High Levels of Microscopic Particulates” just aren’t catchy enough to have become our new nickname. Our air quality slowly improves year after year, but so does our knowledge of the danger of these pollutants. GASP works to reduce emissions from our backyard air pollution sources, such as three nearby coke works (including the largest coke works in the nation), several steel mills, heavy diesel traffic, and many more. We also need relief from upwind sources. We are victims of emissions from power plants in Ohio, in Indiana, in Illinois, and beyond. This rule addresses the entire electricity-generating sector, nationwide, and thus reduces the ability for some to say “Why should we clean up when our neighbors aren’t?” And what do we get by enacting this plan? By 2030, there will be over 50 thousand less tons per year of fine particulates, and over 400 thousand tons per year less sulfur dioxide and nitrogen oxides. These reductions will prevent thousands of premature deaths, half a million missed school and work days, and up to 150 thousand in asthma attacks in children every year. The plan is to be commended for its flexibility. States can use a variety of strategies to meet state-specific goals, and states can also choose to work with neighboring states to create regional plans, if that makes sense to them. The proposal is the result of over a year of direct engagement with stakeholders, and in many ways it’s just the next logical step along a path the states started long ago. Forty-seven states already have demand-side energy efficiency programs. Almost 4 out of every 5 states utilize renewable energy portfolio standards or goals. This proposal builds on the tested, proven successes already achieved by many states. The proposal will save far more in health benefits than its estimated cost. The cost of doing nothing was calculated by the White House Council of Economic Advisers to be 19 times more per year. 19 times more. We cannot afford to wait any longer. What other changes might we see by 2030, beyond much cleaner air and a more stable climate? More creative hydropower projects, like the several that already exist on legacy dams and reservoirs in the region (and the many more being considered). Solar panels on the top of every municipal water tower, county court house, and public works garage. More energy-efficient light bulbs being sold for $1 in thrift stores, like a local electric utility did here recently. More companies using electric power at night to reduce spikes in demand (and to save their company lots of money). Geothermal power projects like in the South Side Library, a 105-year old building that added the technology during a renovation. Vertical axis wind power turbines like the one at Phipps Conservatory, just a few miles from here, or on farms, or in small towns, delivering power to themselves and their neighbors. I see flexibility, efficiency, resiliency, and jobs. Homes, neighborhoods, towns, and cities that are smarter and stronger. Thanks to the Green Building Alliance’s leadership, Pittsburgh is home to one of the nation’s few 2030 Districts. 2030 Districts are voluntary, collaborative efforts where building owners in urban cores agree to slash energy and water use and transportation emissions. We will see states create incentives for more 2030 Districts like Pittsburgh’s. Finally, we will see lots and lots of jobs. Pittsburgh has reinvented itself before and is now poised to take advantage of how this proposal will spur innovation in multiple sectors—from producing cleaner energy, to transmitting it, to using it more efficiently. New techniques and technologies will be needed, ensuring that our nation will be on the leading edge of this advance. Long-term, this proposal will lessen the negative effects of climate change. Short-term, it will spur growth and innovation, secure our position as a leader in future technologies, and save lives. Thank you for the opportunity to comment. Jamin Bogi Policy and Outreach Coordinator Group Against Smog and Pollution 5135 Penn Avenue Pittsburgh, PA 15224 #CO2 #airpollution #sulfurdioxide #JaminBogi #nitrogenoxides #GreenBuildingAlliance #particulatematter

UPDATE 7/3/2014: The County sent its final Air Monitoring Network Plan to the EPA for approval on July 1, 2014. Read our comments and the County’s response, starting on page 88. We are encouraged to see that most or all of our suggestions are being evaluated for potential implementation. Today, GASP sent comments to the Allegheny County Health Department (ACHD) regarding their Air Monitoring Network Plan. We have raised several questions about the locations of certain air quality monitors and the types of air pollution monitored, including: A near-road nitrogen oxides (NOx) monitor is being installed in Wilkinsburg along the Parkway East. The law seems to require another monitor to be installed along with it–one that measures fine particulate matter (PM2.5). The county’s current plan does not include plans for this PM2.5 monitor. Though the Cheswick power plant is the largest source of sulfur dioxide (SO2) emissions in the county, there is no SO2 monitor downwind of the facility. SO2 readings in Glassport were significantly higher than in nearby Liberty, but the county stopped operating the Glassport monitor in 2006. This air pollution can cause or worsen respiratory and cardiovascular disease and even lead to cancer, stroke, and premature death. NOx is also a precursor of ground-level ozone, which causes lung damage, and acid rain. Our region’s residents deserve to know exactly what is in the air they breathe every day. Read our full comments and the ACHD plan. The plan will soon be submitted to the Environmental Protection Agency and GASP will keep you updated on this important issue. #PM25 #airpollution #airmonitoring #AlleghenyCountyHealthDepartment #airquality

The Pennsylvania Department of Environmental Protection (DEP) recently released a proposal that puts emissions limits on some big sources of volatile organic compounds (VOCs) and nitrogen oxides (NOx). These pollutants combine in the atmosphere to create ground-level ozone, a pollutant that burns eyes, triggers asthma attacks, and is even linked to premature death from cardiovascular disease. Ground-level ozone is not a good thing, simply put, and the Pittsburgh region already struggles to meet the federal, health-based standards for ozone levels in the ambient air. So new regulations are good, right? Not yet. In this instance, the DEP proposal will allow much more air pollution to be discharged than is currently being emitted. The proposal sets limits that seem to ignore modern air pollution control technology. Selective Catalytic Reduction units (SCRs) are already installed in many coal-fired power plants in Pennsylvania and all around us. They are reasonably available, technologically feasible, and economically feasible, which are the criteria that DEP must evaluate when making these limits. So why isn’t the DEP setting air pollution limits that consider the best technology? If you’d like to tell the DEP to set tougher limits, please do so by emailing them your comments. After agreeing to their terms, click “Additional RACT Requirement for Major Sources of NOx and VOCs” from the dropdown menu asking which rulemaking you’d like to comment on. Comments will be taken until June 30. Link here: http://www.ahs.dep.pa.gov/RegComments/Agreement.aspx Please let us know if you’d like an explanation of any part of the rulemaking, and we’d love if you shared your comments with us. GASP delivered our own comments in person during a public hearing on 5/27. You can read our comments here. #airpollution #RACTRequirement #VOCs #emissions #DEP

Dues-paying members, please vote by May 28, 2014! Learn more about the candidates here. Ready? Vote! [contact-form-7 404 "Not Found"] #candidates #gaspboard

FOR IMMEDIATE RELEASE May 8, 2014 Contact: John Baillie, Staff Attorney 412-924-0604 john@gasp-pgh.org Group Against Smog and Pollution Files Lawsuit against Shenango, Inc. Plant’s history of air quality violations makes air dangerous to breathe Pittsburgh, PA – Today, the Group Against Smog and Pollution (“GASP”) filed a citizens’ suit under the federal Clean Air Act in the United States District Court for the Western District of Pennsylvania against Shenango, Incorporated (“Shenango”). GASP’s suit includes claims against Shenango based on violations of emissions standards and limitations that have occurred since late 2012 at Shenango’s Neville Island Coke Works. GASP seeks an order of court prohibiting Shenango from violating: Limitations on visible emissions (smoke) from door areas of Shenango’s coke ovens; Limitations on visible emissions from the combustion stack for Shenango’s battery of coke ovens; and Limitations on the sulfur content of the coke oven gas that Shenango flares, mixes, or combusts at the Neville Island Coke Works. Based on compliance reports that Shenango submitted to regulators between July 26, 2012, and September 30, 2013 (a 432-day period), GASP determined that Shenango violated limitations on visible emissions from the door ovens of its coke oven battery at least one time on thirty-nine separate days; violated limitations on visible emissions from the combustion stack for its battery of coke ovens at least one time on 264 separate days; and violated limitations on the sulfur content of its coke oven gas at least one time on twelve separate days. GASP’s suit follows a notice of intent to sue that GASP sent to Shenango (and federal, state, and county officials) on February 6, 2014. Recent government enforcement actions against Shenango, including one concluded by an April 7, 2014 Consent Order and Agreement between Shenango and Allegheny County, either did not address violations of these limitations or imposed measures on Shenango that failed to eliminate Shenango’s violations of the limitations. “The recent agreement between Shenango and the Allegheny County Health Department did not do enough to limit pollution from the coke oven doors or combustion stack,” said Rachel Filippini, Executive Director of the Group Against Smog and Pollution. “These are significant problems, and the longer they go unaddressed, the longer pollution from Shenango continues to make community members sick.” Coke oven emissions, created by Shenango when coal is processed into coke for use in steel making, are some of the most toxic of all air pollutants. These emissions include dangerous pollutants known to cause cancer, asthma, and lung damage. The violations addressed in GASP’s lawsuit have caused emissions of these harmful pollutants to increase. Preventing violations at the Neville Island Coke Works is particularly important given its location: the plant is less than one mile from residential communities along the Ohio River (including Avalon, Ben Avon, Bellevue, Emsworth, and Stowe Township), and is less than five miles from Point State Park in downtown Pittsburgh. “No one should be forced to spend days indoors to protect himself from illegal emissions from Shenango as I have. Given how many people live close to this plant, they should be doing everything in their power to make sure it operates according to the law,” said Ted Popovich, a member of GASP’s board and Ben Avon resident. “It’s great to see GASP moving forward with legal action,” said Angela Garcia, a resident of Bellevue and mother to a son with asthma. “We need all of the problems at Shenango fixed to protect the health of our families.” Valessa Souter-Kline, Outreach Coordinator at PennFuture, added “We all deserve to breathe air that won’t make us sick. As long as Shenango continues to dump toxins into our air, citizens and environmental organizations will continue to work to hold them accountable. They cannot continue to profit at the community’s expense, while operating in violation of regional air quality standards.” GASP is a Pittsburgh-based environmental non-profit founded in 1969 and dedicated to improving air quality in southwestern Pennsylvania and surrounding regions. GASP’s work on this issue has been part of a collaborative effort between several groups to eliminate illegal pollution from Shenango’s Neville Island Coke Works. Participants in the effort include: individuals living near the Shenango facility, GASP, Clean Water Action, Women for a Healthy Environment, Citizens for Pennsylvania’s Future, and Clean Air Council. ### Link to complaint filed May 8, 2014: http://gasp-pgh.org/wp-content/uploads/2008/04/Complaint-re-Shenango-05-08-14.pdf #Shenango #RachelFilippini #emissions #AlleghenyCountyHealthDepartment #NevilleIslandCokeWorks #TedPopovich #airquality

Shenango, Inc. operates a coke manufacturing plant with a 56-oven coke battery on Neville Island in Allegheny County. Shenango manufactures coke by, essentially, baking the impurities out of coal, so that only nearly pure carbon remains. The coke it produces is used in blast furnaces to smelt iron ore. Based on Shenango’s repeated violations of emissions limits established by law and contained in its operating permits, GASP issued a notice of intent to sue Shenango under the federal Clean Air Act and the Allegheny County Health Department’s (“ACHD”) air pollution control regulations on February 6, 2014. GASP’s notice of intent to sue identified more than 300 days between July 26, 2012 and September 30, 2013 on which Shenango violated at least one applicable emission limitation. As required, GASP served copies of its notice on ACHD, the Pennsylvania Department of Environmental Protection, and the United States Environmental Protection Agency, among other government agencies and officials. On April 7, 2014, Allegheny County filed a Complaint against Shenango in the Court of Common Pleas for Allegheny County, Pennsylvania. The County’s Complaint sought a judgment that Shenango violated emissions limitations in its operating permit, as well as an order prohibiting Shenango from operating except in compliance with that permit and the applicable regulations and requiring Shenango to pay a penalty to the Allegheny County Health Department Clean Air Fund. Also on April 7, the County and Shenango entered into a Consent Order and Agreement that purports to settle the claims made in the County’s Complaint. Allegheny County Court of Common Pleas Judge Christine Ward approved the Consent Order on the same day it was executed by Shenango and the County. What does the April 7 consent agreement require and what does it mean? The April 7 consent agreement generally requires Shenango to pay a fine, undertake an investigation, and make a number of changes to its plant and operating methods. Five of the consent agreement’s requirements particularly merit attention. First, the April 7 consent agreement requires Shenango to pay a civil penalty of $300,000 to the Allegheny County Health Department Clean Air Fund. Second, Shenango must complete repairs to its pushing emission control shed and install a shed extension to minimize the size of an existing opening between the plant’s quench tower and main shed. Third, the consent agreement requires Shenango to undertake a “Supplemental Environmental Project,” pursuant to which it must spend at least $285,000 and up to $300,000 to study other physical changes that could be made to the plant’s quench tower to enhance the tower’s ability to control emissions of particulate matter. If that study costs less than $285,000, Shenango is obligated to either spend the difference between $300,000 and the cost of the study on physical improvements to the quench tower or pay it to ACHD as an additional penalty. Fourth, the consent agreement requires Shenango to submit a “Baghouse Maintenance Plan” and “Charging Procedures Work Plan” to ACHD for approval. Following ACHD’s approval of those plans, Shenango must implement them. Fifth, the consent agreement will also force Shenango to maintain a minimum coking time, and increase that time following any rolling three-day period when, on the average, its rate of compliance with applicable limitations on visible emissions falls below 90%. The consent agreement also authorizes Shenango to reduce coking time following periods of three consecutive days when, on the average, its rate of compliance with applicable limitations on visible emissions exceeds 95%. In no event, however, may the coking time be reduced below 17 hours and 30 minutes. What does the April 7 consent agreement fail to do? First, the April 7 consent agreement fails to address at least three aspects of Shenango’s operations that have resulted in repeated violations of applicable emissions limitations. Specifically, the April 7 consent agreement does not require Shenango to implement any new measures to control: 1) visible emissions from its coke oven doors; 2) visible emissions from the combustion stack serving its coke oven battery; or 3) the sulfur content of its flared, mixed, or combusted coke oven gas. This is troubling, because the measures that were in place before April 7 have failed miserably to ensure Shenango’s compliance with applicable limitations on those emissions and limits. Between late July 2012 (when Shenango executed its last consent agreement concerning chronic emissions violations) and the end of September 2013 (the last time covered by compliance reports that GASP currently has), Shenango violated those limitations on at least 300 separate occasions. It would not be unreasonable to conclude that Shenango and ACHD have given up trying to comply with these limitations and are willing to allow violations to continue indefinitely. Second, the April 7 consent agreement fails to impose a fine on Shenango that approaches the maximum fine authorized by law. Although $300,000 is a substantial amount, it pales in comparison to the amount of penalty that ACHD’s regulations and the Pennsylvania Air Pollution Control Act authorized it to impose on Shenango: up to $25,000 per day of violations. Based on the approximately-300 days between July 26, 2012 and September 30, 2013 on which documented violations occurred, ACHD could have imposed on Shenango a penalty in excess of $7,500,000. Third, there is no requirement in the April 7 consent agreement that the required physical alterations and repairs to the plant yield emissions reductions or compliance with applicable emissions standards. Indeed, ACHD may be allowing Shenango to escape full liability for its violations of applicable emissions limitations in exchange for plant upkeep that Shenango would (or should) have performed absent the agreement. Fourth, the consent order does not require Shenango to alter its facility or undertake any operational changes that may be identified by the “Supplemental Environmental Project,” even if those alterations or changes might yield greatly increased compliance or other substantial environmental benefits. Fifth, the consent agreement does not specify what provisions the “Baghouse Maintenance Plan” and “Charging Procedures Work Plan” that Shenango is required to submit to ACHD must include in order to be approved by ACHD. Nor does the consent agreement explicitly require that the plans ultimately yield any actual emissions reductions after they are implemented. It is thus uncertain what, if any, benefits the consent agreement will yield in terms of increased compliance or emissions reductions. Finally, the April 7 consent agreement does not require Shenango to comply with applicable emissions limitations in the law and its current operating permit 100% of the time. Rather, Shenango is authorized to reduce coking times (to its benefit) when the rolling three-day average compliance percentage is as low as 95%. On April 30, representatives from the Allegheny County Health Department will attend a public meeting where they will present the merits of this agreement and what it means for air quality in the region. Please attend if, like us, you have questions about the strength of this agreement. Event details: Wednesday, April 30 6 to 7:30 PM Avalon Borough Building 640 California Avenue Pittsburgh, PA 15202 –post by John Baillie, Staff Attorney #Shenango #JohnBaillie #emissions #AlleghenyCountyHealthDepartment #CleanAirFund #ACHD #airquality #cokeovengas

Title: Public Meeting on Shenango Consent Agreement Location: Avalon Borough Building, 640 California Avenue, Pittsburgh, PA 15202 Description: The Allegheny County Health Department (ACHD) has taken enforcement action against Shenango Coke Works. What’s in the agreement? What does it mean for the Pittsburgh region? Come here from Jayme Graham, the Manager of ACHD’s Air Quality Program, and Dean DeLuca, ACHD’s Enforcement Chief. Bring your questions! For more information, email Julie at jstjohn@cleanwater.org or call at 412.765.3053, x214. Start Time: 18:00 Date: 2014-04-30 End Time: 19:30 #Avalon #consentagreement #Shenango #AlleghenyCountyHealthDepartment #AirQualityProgram #ACHD #airquality

We had to share this testimonial from a teacher participating in our EPA School Flag Program at Colfax Elementary. (Click here to see their press from the launch of the program, which helps teach children about and raise awareness of air quality.) “I wanted to pass along 2 pictures from Education Celebration last night. It’s an event that we have here in our school district where classes or grade levels can showcase things that they have been doing throughout the school year. Naturally, my decision to talk about our air quality project. I have 3 girls there to talk about the flag program and what they do each day to track the air quality. We also have all of our calendars from November until now so that the community could see the amount of green and yellow days that we have had. We have really embraced this project this year and I am so thankful for the opportunity to be a part of it. I had a lot of 4th-grade families stop by and the students were excited because it will be their project next year. We have a banner too on our fence that describes each of the flag colors. Weather depending, I might get that up today. If not I will get it up on Monday. That will help promote the meaning of the flag to the people in the community. I actually had a woman last night get out her phone and call someone and say, ‘I’m hearing them talk about the flag!’ She was really excited which in turn got my students very excited.” #airquality #ColfaxElementary #EPASchoolFlagProgram

In May of 2013, GASP appealed two nearly identical air permits issued by the Pennsylvania Department of Environmental Protection (DEP) for the Forward Compressor Station and the Jefferson Compressor Station, both located in Butler County. We are pleased to announce that after lengthy negotiations, the parties recently reached a settlement agreement that resolves the issues raised in our appeals. These facilities are operated by Mountain Gathering, LLC. Each facility includes eight natural gas compressor engines, three process tanks, one flare, and one TEG dehydrator. GASP appealed these permits because it was not shown that emissions would be minimized as much as possible through the use of the best available technology, as required by law. Additionally, although numerical emission limits were included in the plan approval, there were no physical or operational limits to ensure that the emission limits are met, so the numerical limits were unenforceable. As a result of our appeal, Mountain Gathering will install more effective pollution controls to reduce carbon monoxide, volatile organic compounds (VOCs), and formaldehyde emissions from the compressor engines located at each facility. The revised plan approvals will also include specific conditions requiring the installation and use of these more effective controls. Additionally, the revised plan approvals include lower emission limits for formaldehyde and VOCs. These changes will reduce potential emissions of VOCs, an ozone precursor, by over 40 tons per year, and potential emissions of formaldehyde, a potent carcinogen, by over 8 tons per year. The settlement agreement was finalized on December 3, 2013, and GASP formally withdrew its appeal on December 13, 2013. A copy of the settlement agreement can be found here. #ForwardCompressorStation #JeffersonCompressorStation #VOCs #emissions #DEP #airquality

This past year, GASP continued its important work of fighting for better air quality in Southwestern Pennsylvania with tried-and-true methods as well as utilizing new, innovative strategies. Here are some highlights from our ongoing efforts: Marcellus Shale: With support from Colcom Foundation and YOU, we continue to keep close tabs on natural gas development. Our legal staff has spent much of the past year commenting on and appealing air quality permits related to this industry. These appeals have resulted in strengthened permits that reduce toxic air pollutants and greenhouse gas emissions, necessitate the use of best-available technology, and have made progress toward ensuring that sources of air pollution are aggregated when required by law. Clean Air Dash & Festival: With support from the Heinz Endowments’ Breathe Project, many community and business sponsors, and YOU, we were able to put on a successful 5K. This first-time event celebrated Pittsburgh’s progress in reducing air pollution and challenged all of us to continue our hard work towards better air quality. The event also highlighted our Athletes United for Healthy Air campaign (AU). AU educates athletes about air quality issues in the Pittsburgh region, gives them tools to minimize their exposure, and empowers them to champion for healthy air. This program increases air quality education and awareness among students, and has the potential to improve their health. Youth are disproportionately affected by poor air quality, due to their developing lungs, large lung-to-body weight ratio, and high level of exercise. In addition to the projects discussed above, we continue to advocate for the enforcement of Pittsburgh’s clean construction legislation, track potential changes to the County’s open burning regulation, and conduct educational presentations with students and community groups in the region. Your support is essential to continue all of these important air quality improvement efforts. Please start or renew your membership, or give an additional year-end donation today! Donations can be sent by check or given online by clicking here. Thank you and Happy Holidays! #airpollution #EPASchoolFlagProgram #AirQualityIndex #diesel #CleanConstruction #AirQualityProgram #MarcellusShale #dieselemissions #airquality