That makes 29 exceedances of the H2S standard in the past six months at Allegheny County Health Department’s air quality monitor in Liberty borough. Hydrogen sulfide is a colorless gas recognizable by its rotten egg odor. To put those numbers into perspective: There were just 25 exceedances in all of 2020 and 36 in 2019. “We are now on pace for 59 exceedances this year, which would equal 2017’s total,” GASP staff attorney Ned Mulcahy explained. “It’s difficult to understate how bad exceeding 2017 would be historically: In only four of the past 22 years have there been 60 or more exceedances of the 24-hour h2s standard at Liberty.” GASP is again calling on ACHD to publicly address these mounting exceedances. Residents are regularly afflicted by the onslaught of odors and deserve to know what’s going on at U.S. Steel’s Clairton Coke Works to cause the issue, and what the department is doing to hold the company responsible. There has been no update regarding the April 1 notice of violation (NOV) issued to the company by ACHD for prior exceedances of the hydrogen sulfide ambient air quality standard at the Liberty monitor. That NOV covers 25 exceedances in 2020 and seven more from the first quarter of 2021. It did NOT include eight exceedances of Pennsylvania’s 24-hour H2S standard that occurred at the North Braddock air quality monitor from December 2020 through March 2021. “The health department can’t keep residents in the dark,” GASP Executive Director Rachel Filippini said. “They not only need to provide an update but also what the plan is for improving the situation.” Source: ACHD 2019 Air Quality Annual Report

Proposed permit fee schedule increases expected to put Allegheny County Health Department’s Air Quality Program on sound financial footing are one step closer to final approval. During the Allegheny County Council meeting Tuesday afternoon, the measure was referred to the committee on health and human services. GASP has long championed the revised fee schedule, which mostly mirrors those approved by the state that went into effect this past January. The Allegheny County Board of Health in March voted to push the changes forward to county council. When finally approved, the fee schedule would increase application fees for plan approvals, operation permits, and the annual administration fees charged to operating permit holders that were based on a schedule set all the way back in the 1990s and last increased 14 years ago. The proposed fee schedule is tiered. The first set of increases going into effect 60 days after final adoption through 2025. The fees then increase in 2026 and then again in 2031. If finally approved, the plan would for the first time impose fees on major and minor sources of air pollution seeking: revisions to plant-wide applicability limits; ambient air impact modeling completed in connection with certain plan approval applications; risk assessments; and requests for determination GASP Executive Director Rachel Filippini was among those who submitted public comments in support of the proposed changes. “It’s important to understand that the Clean Air Act requires that the fees imposed on Title V sources in Allegheny County be ‘sufficient to cover all reasonable (direct and indirect) costs required to develop and administer’ the health department’s Title V permit program,” she explained. “Because ACHD’s Air Quality Program receives little or no funding from Allegheny County itself, that means the fees paid by non-Title V sources in the County must also generate sufficient revenue to fund the non-Title V side of the Program – making these changes absolutely imperative.” You can read her full comments here. If you haven’t already signed our petition urging council to approve the fee schedule changes when it comes up for a final vote, you can – and should – do so now. Here’s more info for those who’d like more background.

UPDATE: There was another hydrogen sulfide exceedance at Allegheny County Health Department’s air quality monitor in Liberty Borough Monday – making 27 so far this year. Allegheny County experienced its 26th hydrogen sulfide exceedance of the year Friday when concentrations of the colorless gas recognizable by its rotten-egg odor surpassed the state’s 24-hour-average standard at the Liberty monitor in the Mon Valley. That makes 26 such exceedances so far in 2021. That means: There have already been more exceedances in the first half of 2021 than in all of 2020 at the Liberty air quality monitor There has been more than one exceedance per week on average in 2021 so far at Liberty air quality monitor Since March 3, there has been nearly one exceedance every four days But that’s not all. “There have also been 10 exceedances so far this year at Allegheny County Health Department’s North Braddock air quality monitor, which itself is nothing to ignore considering H2S wasn’t previously even monitored there,” GASP Executive Director Rachel Filippini explained. GASP is again asking the health department: What’s going on at U.S. Steel’s Clairton Coke Works? ACHD on April 1 issued a notice of violation against the company for exceedances of the hydrogen sulfide ambient air quality standard at the Liberty monitor.  That NOV covers 25 exceedances in 2020 and seven more from the first quarter of 2021. It did NOT include eight exceedances of Pennsylvania’s 24-hour H2S standard that occurred at the North Braddock air quality monitor December 2020 through March 2021. “Since then, the health department has provided no new details related to the ongoing H2S exceedances or what actions – if any – U.S. Steel is taking to prevent more of them in the future,” Filippini said. “Residents deserve to know when they can expect a reprieve from the ongoing stench from the mill.”

The Group Against Smog and Pollution (GASP) on Wednesday presented verbal testimony at a public hearing regarding Allegheny County’s draft episodic weather regulations. The hearing, which was held online, featured numerous speakers who shared their concerns about the rules and recommendations to make them more protective of public health. Please note that while the hearing is over, ACHD is accepting comments through 11:59 p.m. tonight, Wednesday, June 9. We have everything you need to know about the regs, sample comment language, and a form that will route them straight to the health department. You can check all that out here. Here’s what our staff attorney Ned Mulcahy presented at the hearing: Good evening. My name is Ned Mulcahy and I am speaking on behalf of Group Against Smog and Pollution. Later tonight we will be submitting formal written comments on the proposed Mon Valley Air Pollution Episode – along with a copy of this testimony. In January 2020, ACHD announced it would: “propose a new air quality regulation in 2020 aimed at emission mitigation requirements for industry operating in the county during weather-related pollution episodes.” Considering all that’s happened between then and now, we want ACHD and the Air Quality Program to know how much GASP appreciates their efforts. As for the regulation itself, GASP is largely in support of its approach and aims. EPA’s first air pollution episode regulations were published in 1971. A guidance document published at that time reasoned that: “[s]ince stagnant air masses will prevent dilution of pollutants, the only feasible method for protecting society is to minimize the flow of pollutants from emitters.” It appears the Pollution Mitigation Plans will accomplish that, but we encourage ACHD to consider amending the rule to spell out more clearly the levels of reductions required. Two concerns we want to highlight now have to do with the “Mon Valley PM2.5 threshold level.” There is no clear basis for requiring that pollution reduction measures only begin if or after the 24-hour NAAQS level is exceeded. NAAQS revisions since 1999 typically have included revisions to the “break-points” in AQI categories. But that is at least partially for simplicity and consistency in messaging. In the 2015 Federal Register notice addressing the revised ozone NAAQS, the EPA cautioned against using the AQI category “break-points” as a guide for making policy decisions on controlling emission sources when poor air quality is likely to occur. EPA said: “State, local and tribal agencies should consider whether non-voluntary emissions or activity curtailments are necessary (as opposed to a suite of voluntary measures) for days when the AQI is forecasted to be on the lower end of the moderate category.” Regarding pm2.5, the “moderate” AQI range corresponds to concentrations of 12.1 – 35.4 ug/m3. Even if ACHD sticks with the 35.5 ug/m3 threshold level, ACHD must consider an additional threshold level for shorter-term, high levels of PM2.5. In its 2019 review of the particulate matter NAAQS, EPA documentation showed that there are potential health consequences of exposure to even two hours of PM2.5 at or around 100 ug/m3. The EPA chose not to alter the NAAQS methodology – essentially —because of its position such exposures would only likely occur in non-attainment areas and already be addressed. As noted above, the NAAQS need not be followed as a guide for the rule. But of greater importance is that on April 24, 2021, pm2.5 at Liberty averaged 100 ug/m3 over three hours (4a to 7a). The 24-hour average on that day was just 32.5 ug/m3 – below the NAAQS level. ACHD’s must act to protect the health, safety, and welfare of all its citizens and examine an approach to addressing this issue even if EPA did not.

The Allegheny County Health Department (ACHD) on Wednesday issued a press release regarding a demand for stipulated penalties it issued on June 4 against U.S. Steel in the amount of $201,500. You can read the enforcement action here. Check back, we will update this blog with reactions and links to associated news stories. The Allegheny County Health Department issued $201,500 worth of stipulated penalties against U.S. Steel for Article XXI Air Pollution Control violations and permit violations that occurred at the Clairton Coke Works during the first quarter of 2021 and through March 31, 2021. Pursuant to the Department’s agreement that was reached with U.S. Steel in June of 2019, ninety percent (90 percent) of penalties ($181,350) will be paid to the Community Benefit Trust for impacted communities while the remaining 10 percent ($20,150) will be paid to the Clean Air Fund. To view this enforcement action and other air quality enforcement actions issued by ACHD, click here. “Here we go again,” GASP Executive Director Rachel Filippini said. “Despite U.S. Steel’s repeated bragging about what it sees as an outstanding environmental record, the company still gets dinged for air quality violations quarter after quarter.” She added: “Few who breathe Mon Valley air will be surprised to hear U.S. Steel was fined for emissions issues at its facilities.”

The colorless gas is most commonly recognized by its “rotten egg” odor and concentrations exceeded the Pennsylvania 24-hour average standard of 0.005 ppm on both Saturday (0.007 ppm) and Sunday (0.009 ppm) at Allegheny County Health Department’s air quality monitor in Liberty borough. “There have been 24 H2S exceedances so far this year at Liberty. That’s only one less than in all of 2020, but it’s also worth noting that the first exceedance in 2021 at that monitor didn’t occur until March 3,” GASP staff attorney Ned Mulcahy explained. “In other words, there has been an average of one H2S exceedance every fourth day for the past three months. That’s downright awful.” The spate of exceedances so far this year begs the question: What is going on at U.S. Steel’s Clairton Coke Works? The Allegheny County Health Department on April 1 issued a Notice of Violation against the company for exceedances of the hydrogen sulfide ambient air quality standard at the Liberty monitor. That NOV covers 25 exceedances that happened in 2020 and seven more from the first quarter of 2021. It did NOT include eight exceedances of Pennsylvania’s 24-hour H2S standard that occurred at the North Braddock air quality monitor December 2020 through March 2021. Procedurally, U.S. Steel had 14 days to schedule a meeting with ACHD to discuss the NOV before the department could proceed with further enforcement action. But since the NOV was issued, there have been 17 more H2S exceedances. GASP submitted a formal Right to Know request for information related to the NOV and was provided little new information. However, we did receive copies of internal emails showing Allegheny County Chief Executive Rich Fitzgerald is aware of – and concerned about – the problem despite making no public statements about the ongoing air quality issue facing his constituents. In an email to ACHD Deputy Director of Environmental Health Jim Kelly, the department’s Chief Operating Officer Patrick Dowd wrote: “The County Executive was clearly frustrated that US Steel could meet the three-year emissions average yet still emit so much PM2.5 that people could be choking in a given set of hours. He clearly wants to find a way to encourage the company to do the right thing for public health as you and your team pursue the longer term strategies related to regulatory changes. Once you and your team have conferred, please, let’s you and I talk later today. Thank you, Jim. This work is extremely important, as the County Executive clearly said on the call.” You can read the entire email here: GASP is again calling on ACHD and Fitzgerald to provide a substantive update to residents on what is causing the H2S – as well as other air quality issues in the Mon Valley – and what transpired between when the NOV was issued and now. “The public has had to deal with pervasive rotten egg odors from H2S this entire spring yet has received zero updates from the health department,” GASP Executive Director Rachel Filippini said. “H2S in the Mon Valley is a problem that’s getting worse, not better. It’s well past time for the health department and County Executive Fitzgerald to provide residents with an update on what’s being done to remedy this quality-of-life issue impacting far too many who live in Allegheny County.”

Editor’s Note: The public comment period for Allegheny County’s draft episodic weather regulations is now closed. Thank you to everyone who took the time to submit comments! We will continue to follow the issue – check back for updates. A proposed change to Allegheny County’s Air Pollution Control Regulations aims to reduce particulate matter pollution in the Mon Valley during periods of stagnant weather patterns often a factor in poor air quality as well as exceedances of state and federal air quality standards. The new regulation will require facilities in the defined area that produce more than 6.5 tons of pm2.5 annually and/or more than 10 tons of pm10 annually to create and submit to the Allegheny County Health Department (ACHD) “Mitigation Plans” for periods when poor air quality is forecast. ACHD predicts this will affect 18 facilities in the 32 listed municipalities. During the “Watch” phase, facilities such as U.S. Steel’s Clairton Coke Works must conduct basic checks to ensure equipment is in good working order but also ensure they have adequate staff to take actions required under the “Warning” phase. Once a “Warning” is issued, facilities must undertake the actions listed in the mitigation plans they filed with ACHD. The specific actions will be catered to each facility and approved on a case-by-case basis. Although the bulk of the regulation addresses industrial sources of particulate matter pollution, the proposed change will also ban all wood-burning activities when a Mon Valley Air Pollution Watch or Warning has been issued in the defined municipalities. The County currently has regulations that cover episodes of poor air quality but they are so outdated they don’t even include actions to reduce levels of pm2.5, a substance the EPA first created an ambient air quality standard for in 1997. GASP began calling on ACHD to strengthen the county’s episodic weather regulations in December 2019, when a prolonged inversion prevented air pollution from dissipating, resulting in local air quality exceeding the federal air quality standard for fine particulate matter six days in a row. During that same period, the region’s air quality exceeded the Pennsylvania state standard for hydrogen sulfide (H2S) eight days in a row. “The regulations are a positive step but a few concerns remain,” GASP Executive Director Rachel Filippini said. “Namely, the level of reductions required by the mitigation plans are not spelled out and the Warning phase will only begin after a rolling 24-hour average level of pm2.5 exceeds the federal standard.” GASP is concerned that no actual reductions in pollution emissions are required during the Watch phase, a period when all signs – and ACHD – are pointing to a period of poor air quality. “The county has been aware of the woefully outdated regulations for decades – it’s imperative that ACHD get it right,” Filippini said. “Industrial polluters need to be accountable for the emissions they spew during these bad weather events. Residents deserve that much and more.” We encourage you to let ACHD know what you think about the regulations. The full text of the proposed changes, ACHD’s memo supporting the regulation, and instruction for submitting comments are all available online here: https://www.alleghenycounty.us/Health-Department/Programs/Air-Quality/Regulations-and-SIPs.aspx Comments are due June 9.

It was another weekend of poor air quality for Mon Valley residents: The Liberty-Clairton area (again) had the worst AQI in the country Saturday morning when it soared into the red, unhealthy-for-all range. Allegheny County also tallied two more air quality exceedances over the weekend, when concentrations of hydrogen sulfide exceeded Pennsylvania’s 24-hour average standard of 0.005 ppm at the Liberty monitor Friday (0.007 ppm) and Saturday (0.012 ppm). The latest bout of poor air quality pushed exceedances at the Liberty monitor to 22 so far this year. By contrast, there were 25 such exceedances at the Liberty monitor in ALL of 2020. Hydrogen sulfide is a colorless gas most commonly recognized by its “rotten egg” smell. This puts us on track to average at least one H2S violation per week, back to where it was in 2019. Numbers like that suggest air quality in 2020 was anything but typical and calls into question the County’s press release earlier this year that stated air quality was still on track to attain the federal standards in 2020 even without lower levels of pollution due to the pandemic. This also calls into question what’s been going on at U.S. Steel’s Clairton Coke Works so far in 2021. The Allegheny County Health Department on April 1 issued a Notice of Violation against the company for exceedances of the hydrogen sulfide ambient air quality standard at the Liberty monitor. The NOV covers 25 exceedances that occurred in 2020 and seven from the first quarter of 2021. The notice is the first step for any enforcement action, including civil penalties of up to $25,000 per violation per day, for sources. Eight exceedances of the state’s 24-hour H2S standard that occurred at the North Braddock monitor December 2020 through March 2021 were not included. Procedurally, U.S. Steel had 14 days to schedule a meeting with ACHD to discuss the NOV before the department could proceed with further enforcement action. “Since the NOV was issued, there have been 15 more H2S exceedances at Liberty and zero additional information from the health department,” GASP Executive Director Rachel Filippini said. “It’s been nearly two months since the enforcement action was filed, the public deserves an update.” She continued: “ACHD has a duty to provide residents with timely public communications regarding extended bouts of unhealthy air quality and how it could impact their health and that of their families,” Filippini said. “We appreciate that the health department has started to address poor air quality in the Mon Valley via social media, but all too often those communications come too late to help residents make decisions that could help mitigate their exposure to unhealthy air.” Editor’s Note: GASP has submitted a state Right to Know request related to the April 1 NOV and will provide more information if and when it is granted.

A cornerstone of GASP’s clean air advocacy is watchdog work. We keep a close eye on more than just air quality data and emissions emanating from industrial polluters – we also work to keep air quality regulators accountable. Here in Allegheny County, that means keeping track of how efficiently our air local quality regulator – the Allegheny County Health Department (ACHD) – is managing the issuance of new air quality permits and the renewal of old ones. GASP’s legal team first sounded the alarm about a backlog of applications for new or renewed Title V permits for major sources of air pollution in Allegheny County back in 2016. Since then, we’ve provided periodic updates about ACHD’s efforts to whittle down that backlog, and even expanded our watchdog work to include information regarding the state Department of Environmental Protection’s permit backlog, as well. “Our investigation found that while strides have been made at both the county and state level to reduce the backlog, there are still too many major sources of air pollution currently operating under an old permit – and some that are operating without any operating permit,” GASP Executive Director Rachel Filippini said. Here’s what our research uncovered: Understanding Title V Operating Permits: What They Are, Who Needs Them, and Rules About How They’re Issued Operating permits for major sources of air pollution are required by Title V of the Clean Air Act, and thus are commonly called “Title V Operating Permits.” A Title V Operating Permit for a particular facility must contain all of the operating requirements that the air pollution laws impose on the facility. This helps facilitate compliance with those requirements – both regulators and the public can use a facility’s Title V Operating Permit to determine what requirements it has and to help determine whether or not it is complying with them. A major source must apply for a Title V Operating Permit once it begins normal operations. Good for five years, sources must apply to renew their Title V Operating Permits before their old ones expire. The Clean Air Act, Pennsylvania’s air pollution control rules, and Allegheny County’s air pollution control regulations all require that the agency responsible for issuing Title V Operating Permits complete its review of any complete permit application within 18 months. Notably, the Clean Air Act permits a source that has submitted a complete application for a Title V Operating Permit to continue to operate pending the responsible agency’s final approval of the application, even if agency approval takes years. The Clean Air Act also requires that the operations of the state and local programs that administer Title V Operating Permits be funded entirely from the emissions and permit fees paid by the sources subject to the requirements of Title V. We first blogged about the backlogs of applications for new and renewed operating permits for major sources of air pollution that existed in Allegheny County, where such sources are regulated by the Allegheny County Health Department (ACHD) and the Pennsylvania Department of Environmental Protection’s (DEP) Southwest Regional Office in September 2016. In April 2018, we updated that research and expanded it to include sources permitted by DEP’s other five regional offices. We updated that research again in April 2019, following a proposal by Pennsylvania’s Environmental Quality Board to amend the fee schedule for permits issued by DEP’s Air Quality Program, and again in June 2020. For those who haven’t been following the issue: DEP sought to amend the fee schedule for the Air Quality Program because the program was running out of money and purportedly faced budget cuts that would make it difficult or impossible for the program to carry out its work. The proposed revisions to DEP’s air quality fee schedule finally became effective this past January. “Going forward, the Air Quality Program should not be hamstrung by lack of resources caused by inadequate revenues,” GASP senior attorney John Baillie explained. “Although it is probably too early for any benefits from increased revenues from the new fee schedule to be reflected in current backlog totals, this year’s totals could serve as a baseline in future years for judging the effectiveness of the fee schedule at providing the Air Quality Program with the resources it needs to do its job.” ACHD approved fee schedule revisions that closely track DEP’s in 2021, so when they are finally approved by the county, ACHD should similarly have adequate resources going forward to do its job. We updated our research on the backlogs again this year.  Here’s what we found: This year, there are now 24 major sources of air pollution in Allegheny County. Of those, two have never been issued Title V Operating Permits – Allegheny Ludlum’s Brackenridge Works and Eastman Chemicals & Resins. Eastman Chemical is subject to a 2011 federal and state consent decree that has a direct impact on its air quality permits and that effectively precludes the issuance of a Title V Operating Permit until it has been satisfied (which has yet to occur). Further, ACHD has failed to act on renewal applications for another one of those 24 major sources within 18 months as its regulations require. For purposes of air quality permitting, DEP’s Southwest Regional Office includes sources in Beaver, Cambria, Greene, Somerset, Washington, and Westmoreland Counties. It’s important to note that responsibility for administering the Title V permitting program for sources in Armstrong and Indiana Counties was transferred in early 2019 from Southwest Regional to DEP’s Northwest Regional Office. We currently count 50 major sources in the Southwest Region, with nine of those having renewal applications for operating permits that have been pending for more than 18 months. One other source in the southwest Region – the Brunner Landfill – has never been issued a Title V Operating Permit. In addition to Armstrong and Indiana Counties, the Northwest Region Office is also responsible for Title V permitting for Butler, Clarion, Crawford, Elk, Erie, Forest, Jefferson, Lawrence, McKean, Mercer, and Venango Counties. There, we count 68 active major sources of air pollution. One of those 68 facilities has had a renewal application for its Title V Operating Permit pending for more than 18 months. DEP’s Northcentral Region includes Bradford, Cameron, Centre, Clearfield, Clinton, Columbia, Lycoming, Montour, Northumberland, Potter, Snyder, Sullivan, Tioga, and Union counties. We counted 54 major sources of air pollution in the Northcentral Region – none of them have a renewal application that has been pending for more than 18 months and all sites in the region either have a current Title V Operating Permit, or submitted an application for a renewal within the last 18 months. DEP’s Southcentral Region includes Adams, Bedford, Berks, Blair, Cumberland, Dauphin, Franklin, Fulton, Huntington, Juniata, Lancaster, Lebanon, Mifflin, Perry, and York counties. We counted 114 active major sources of air pollution in these counties, none of which has had a renewal application for a Title V Operating Permit pending for more than 18 months. All major sources in DEP’s Southcentral Region either have a current Title V Operating Permit or submitted a renewal application within the last 18 months. DEP’s Northeast Region includes Carbon, Lackawanna, Lehigh, Luzerne, Monroe, Northampton, Pike, Schuykill, Susquehanna, Wayne, and Wyoming counties. We counted 62 active major sources of air pollution in those counties, two of which have had applications for their Title V Operating Permits pending for at least 18 months. The American Zinc Recycling facility is subject to a proposed Consent Decree with the United States and DEP that involves violations of the air pollution laws. Presumably, the Title V Operating Permit for that facility will not be renewed until that Consent Decree is finalized and its terms can be incorporated into the permit. DEP’s Southeast Region includes Bucks, Chester, Delaware, and Montgomery counties for purposes of permitting sources of air pollution. Philadelphia’s Air Management Services administers the Title V permitting program for facilities located in Philadelphia. We counted 88 active major sources of air pollution in the Southeast Region, three of which have had renewal applications for Title V Operating Permits pending for more than 18 months.

AQI soared into the red, unhealthy-for-everybody range this morning, peaking at 163. An air dispersion report issued Wednesday by the Allegheny County Health Department (ACHD) noted a strong surface inversion occurred today. The forecast, sourced from the state Department of Environmental Protection (DEP) said: Fine particulate levels will be at their highest between 4 and 10 a.m. this morning, then the breaking inversion along with a southeast wind will send overall averages down into the mid to high moderate range for the overall daily average. While Wednesday’s report called for somewhat better air dispersion conditions for tomorrow morning, it did forecast another moderate-to-strong surface inversion early Thursday. But it wasn’t just fine particulate levels that were elevated in the Mon Valley this week – concentrations of hydrogen-sulfide (called H2S for short, it’s a colorless gas recognized by its distinct rotten-egg odor) were also high. In fact, the 24-hour average concentration of H2S at ACHD’s air quality monitor in Liberty Borough was 0.009 ppm Tuesday, exceeding Pennsylvania’s standard of 0.005 ppm. Levels of hydrogen sulfide at the Liberty monitor were so high Wednesday that by 8 a.m. another exceedance was guaranteed. That means that on four of the last six days, levels of H2S were over the regulatory limit, and the intervening days weren’t much better: The average concentration at the Liberty monitor was 0.005 ppm on both May 16 and May 17. Over this same six-day period, concentrations at the North Braddock monitor flirted with regulatory limits but did not exceed them. “How many more hydrogen-sulfide exceedances need to happen in the Mon Valley before the Allegheny County Health Department provides an update on the enforcement order it issued to U.S. Steel over this very issue?” GASP Executive Director Rachel Filippini asked. By way of background: GASP has long called on ACHD to track down the source of the county’s H2S problem, and on April 1 the department finally took action, issuing a Notice of Violation to U.S. Steel covering 25 exceedances that occurred in 2020 and seven in the first quarter of 2021 at the Liberty monitor. Eight exceedances of the state’s 24-hour H2S standard that occurred at the North Braddock monitor December 2020 through March 2021 were not included. This type of notice is the first step for any enforcement action – including civil penalties of up to $25,000 per violation per day – for air pollution sources. U.S. Steel had 14 days to schedule a meeting with ACHD to discuss the NOV before ACHD may proceed with further enforcement action. No further information about the notice or U.S. Steel’s response is available on the ACHD website. GASP submitted a formal Right to Know request to glean more information and will provide an update when that request is granted.