The Group Against Smog and Pollution on Thursday submitted formal public comments on the much-delayed - and long-awaited - Title V Operating Permit for Jefferson Hills chemical-manufacturing facility Synthomer, Inc. And when we say “much-delayed” we mean it: Synthomer (formerly Eastman Chemical) is one of two major sources in Allegheny County that has never been issued a Title V Operating Permit, despite ACHD regulations that provide that such a permit should have been issued by the end of 2003 (the other is ATI Brackenridge Works). Crazy, right? We thought so, too. Our senior attorney John Baillie has been sounding the alarm over the Title V permit backlog at the health department since 2015 - and this was one of the facilities that GASP has kept its eye on over the years. For Synthomer, it’s been a rocky road on the permit front. To catch up briefly: A LONG time ago, the facility was caught violating numerous air pollution regulations, and subjected to a December 2011 consent order in federal court that required it to do: comprehensive emissions testing on all of its sources of air pollution submit the results of that testing to the Allegheny County Health Department and the EPA for review apply to ACHD for an installation permit for each source after receiving EPA approval of the test results and – once all sources were under installation permits - apply for a Title V operating permit. Back to the subject at hand: Our comments on the draft permit, which can be read here. The long and short of it? “It’s about damn time,” GASP Executive Director Patrick Campbell said. “This permit assures an additional level of accountability and transparency that was lacking for so long.” Baillie agreed. “It’s been a long time coming, but the process to get to this point has led to a permit that finally brings all of this facility's operating requirements under one umbrella in the same document, which should make it easier for ACHD and anyone interested to determine the plant's compliance with those requirements."

Photo by GASP Board Member Roger Day Editor’s Note: This blog was updated at 4:20 p.m. Nov. 7 to include additional information from the state Department of Environmental Protection. Allegheny County Health Department (ACHD) Sunday morning issued a Mon Valley Air Pollution Warning, with preliminary data showing levels of fine particulate matter exceeded federal health-based air quality standards at its Liberty monitor. According to airnow.gov, the NowCast Air Quality Index (AQI) in the Mon Valley at one point Sunday morning soared to 175, which the Environmental Protection Agency (EPA) classifies as “unhealthy.” During periods of unhealthy air quality, the EPA suggests that people with heart or lung disease, older adults, children, and teens should avoid strenuous outdoor activities, keep outdoor activities short, and consider moving physical activities indoors or rescheduling them to reduce exposure to air pollutants. In its Mon Valley Air Pollution Warning alert, ACHD told residents: An Air Pollution Warning has been issued for the Mon Valley. The 24-hour PM2.5 standard for the Mon Valley has been exceeded at an official monitoring station in the Mon Valley and is likely to continue.Young children, the elderly, and those with respiratory problems, such as asthma, emphysema, and bronchitis, are especially vulnerable to the effects of air pollution and should limit outdoor activities during this time. Companies contributing to pollution can contribute by temporarily reducing activities that produce emissions.More information about fine particulate matter (PM2.5), as well as the current monitored values can be found at: https://www.alleghenycounty.us/Health-Department/Programs/Air-Quality/Air-Quality.aspx But particle pollution wasn’t the only concern: Concentrations of hydrogen sulfide (H2S) at the Liberty monitor were also alarmingly high Sunday – so high that an exceedance of the state 24-hour average was guaranteed by 10 a.m. That makes 41 such exceedances at the Liberty monitor so far this year. There have been another 15 H2S exceedances at ACHD’s air quality monitor in North Braddock. Conditions are predicted to improve today but could remain a concern through Tuesday, the extended forecast on airnow.gov offering an optimistic but inexact: “Good air quality may return by the mid-week period.” The state Department of Environmental Protection on Sunday afternoon issued a Code Orange Air Quality Action Day for the Liberty-Clairton area Monday. You can get all the details on that here. GASP will continue to monitor the data and will update this blog if/when new information is available.

Longtime GASP partner Levin Furniture has just installed a 1-megawatt array of 2,500 solar panels atop its warehouse and corporate headquarters in Smithton. A “Flip the Switch” ceremony to turn on the system will be held at Levin’s warehouse at 11 a.m. Wednesday. “This project continues our investment in the company and adds to several important environmentally responsible practices at Levin’s,” Levin Chairman Robert Levin said in a release. The new 1 MW array is the fifth rooftop solar project completed by Levin’s. The local family business is believed to be the first furniture company in the United States to use solar power with its 2004 installation at its Monroeville location. Levin Furniture was recognized in 2008 by the State of Pennsylvania with its “Waste Watchers Award” given to organizations that have shown leadership in recycling and other environmental initiatives. As the largest solar installation by a retail company in western Pennsylvania, the system will generate 70 percent of the distribution center’s annual electricity needs, or enough to power approximately 100 homes. In one year, that equates to eliminating roughly 824 tons of CO2, or 1,738 barrels of oil. Solbridge Energy Advisors was tapped to serve as the project consultant, broker, and owner’s representative. Solbridge worked with Levin leadership on all aspects of the project. Paradise Energy Solutions constructed the solar array. “Levin has long been a supporter of GASP and a business that has led by example when it comes to green initiatives,” GASP Executive Director Patrick Campbell said. “We thank them for their corporate leadership.”

For the third day in a row, hydrogen sulfide (H2S) levels were so high Tuesday that an exceedance of Pennsylvania’s 24-hour average was guaranteed by 10 a.m. at Allegheny County Health Department’s air quality monitor in Liberty Borough. Tuesday’s exceedance will mark the 43rd of the year at the Liberty monitor. There have been 16 such exceedances at ACHD’s air quality monitor in North Braddock, the most recent of which occurred Monday. Unfortunately, the Mon Valley grappled with more than just high levels of H2S over the past few days: It also endured an exceedance of the federal, health-based standard on Sunday for fine particulate matter, also known as PM2.5, based on preliminary data from ACHD’s Liberty Borough monitor. For perspective on how bad air quality has been lately, the airnow.gov NowCast Air Quality Index (AQI) ranked Liberty-Clairton’s as the worst air quality in the country at times on Sunday, Monday, and today, when it soared to levels deemed “unhealthy” by the U.S. Environmental Protection Agency. During periods of unhealthy air quality, the EPA suggests that people with heart or lung disease, older adults, children, and teens should avoid strenuous outdoor activities, keep outdoor activities short, and consider moving physical activities indoors or rescheduling them to reduce exposure to air pollutants.

The U.S. Environmental Protection Agency (EPA) in September announced that the agency intends to make a Clean Data Determination regarding levels of fine particulate matter (PM2.5) in Allegheny County. This means the EPA determined the three-year average PM2.5 concentration was below the annual federal standard of 12.0 micrograms per cubic meter (µg/m3) based on “quality-assured, quality-controlled, and certified ambient air quality monitoring data” from 2018 to 2020. Clean Data and Air Quality Standards Setting aside the issue of whether the EPA’s current annual PM2.5 standard is truly protective of public health, Clean Data alone is not the final word on Allegheny County complying with that standard. At an Oct. 12 meeting, Allegheny County Health Department (ACHD) staff laid out several issues the department still must address before EPA classifies Allegheny County as officially “attaining” the National Ambient Air Quality Standard (NAAQS) for PM2.5. Even for regular attendees of these meetings, it was a lot to take in. Given the complexity of the issue and the fact we get a lot of questions about how air quality standards work, we thought explaining what the meeting covered and related implications for Allegheny County “attaining” the NAAQS would be helpful. To start, it will be useful to understand how the EPA designated Allegheny County as a “nonattainment” area in the first place. For air pollutants throughout the country that “may reasonably be anticipated to endanger public health or welfare,” the Clean Air Act requires the EPA to create NAAQS that, after “allowing an adequate margin of safety, are requisite to protect the public health.” In 2012, the EPA lowered the annual PM2.5 NAAQS from 15.0 to 12.0 µg/m3. EPA stated at the time that the lower standard would “provide increased protection for children, older adults, persons with pre-existing heart and lung disease, and other at-risk populations against an array of PM2.5-related adverse health effects.” According to the EPA, those adverse health effects may include premature mortality as well as “aggravation of respiratory and cardiovascular disease, changes in lung function, and increased respiratory symptoms.” Having lowered the standard, the next step was for states to assess and determine what areas were not meeting the new standard. For prior NAAQS (both PM2.5 and other pollutants), the state and county have carved out specific locations (e.g., “Liberty-Clairton” or “Pittsburgh-Beaver Valley”). In this case, Allegheny County was assessed on the whole. In January 2015, EPA published a complete list of annual average PM2.5 levels for these areas covering the years 2011 to 2013. All locations below 12.0 µg/m3 were considered “attainment” areas and locations exceeding the NAAQS were labeled nonattainment areas. Allegheny County – at 13.4 µg/m3 – became a “nonattainment” area. To ensure that we, as well as more than 300 million other Americans, are breathing “attainment” level air, the EPA relies on more than just the shame of the nonattainment label: The Clean Air Act demands that states with nonattainment areas create, submit for approval, and stick to what’s known as a State Implementation Plan (SIP) that will guarantee eventual compliance with the NAAQS. Implementing a Plan for Cleaner Air Creating a SIP is a massive undertaking that involves monitoring, modeling, and tracking emissions sources, and then creating a comprehensive plan to reduce emissions to a point that ensures ambient air quality ends up below the NAAQS. “Think of a SIP as a federally enforceable diet. An area being labeled ‘nonattainment’ suggests it has indulged in too many poor practices for too long. To reach a healthier state of affairs, certain restrictions, reductions, and sacrifices must be made,” GASP staff attorney Ned Mulcahy explained. And *here* is where things get complicated. ACHD missed the deadline for submitting its SIP to the EPA. It was late, but “complete,” which is important. A “complete” SIP (i.e., it addressed all the required elements) meant ACHD would not immediately face sanctions such as reductions in federal highway funding or higher required emissions offsets for new sources (spoiler: sanctions come up again later). Unfortunately, “complete” and “adequate” are different adjectives. As for its adequacy, EPA only “conditionally” approved ACHD’s SIP on May 14. The “conditional” part means ACHD still has work left to do. Specifically, EPA took issue with the contingency measures in ACHD’s SIP. Such measures are back-up pollution reduction methods triggered only if the county is failing to make progress or meet milestones described in the SIP. ACHD originally proposed using the reduction in emissions expected from the July 27, 2019, Settlement Agreement with U.S. Steel concerning emissions from its Clairton Coke Works. The EPA denied the request, responding, “[m]easures that will be implemented regardless of being triggered [by an under-performing SIP] are not considered appropriate to use as contingency measures.” “To keep running with the diet analogy: if you aren’t hitting your goals you need to have a back-up plan that is a true change of course, not something that was going to occur anyway,” Mulcahy said. In its May 2021 conditional SIP approval notice, EPA demanded that ACHD adopt specific contingency measures from a list specified in this letter that will provide for a reduction of up to 34 tons per year of direct PM2.5 emissions. Failure to do so by May 2022 would reintroduce the possibility of sanctions that we mentioned earlier. Allegheny County’s Attainment Options With all of that hanging in the balance, remember Clean Data? This is a story about Clean Data. The timing of the Clean Data Determination meant – in essence – that before EPA could give final approval to ACHD’s “diet,” the county met its goal…sort of. In its September 2021 Clean Data proposal, EPA said final approval of the Clean Data Determination would “suspend the requirements” that ACHD finalize its SIP measures “related to the attainment of the 2012 annual PM2.5 NAAQS.” But this came with one HUGE contingency: The suspension lasted only “so long as the area continues to meet the NAAQS, [or] until the area is redesignated to attainment.” The problem is that falling off the wagon (so to say) – ending up with a three-year average PM2.5 level above 12.0 µg/m3 for 2019 to 2021 or 2020 to 2022 – is still possible. If that were to happen, the suspended requirements would become due, and again possibly cause EPA to impose sanctions. By all accounts, ACHD plans to move ahead with the next step after a Clean Data Determination: formally requesting EPA redesignate Allegheny County as an attainment area. This request would include ACHD developing an approved maintenance plan, which – ironically – must include a set of “contingency” provisions. To the best of our knowledge, ACHD also is working on the SIP contingency revisions. But with a lot of work to do and limited resources, the department could gamble on getting back into attainment (officially) or keeping Clean Data and hope any future hiccups fall under the maintenance plan. It seems to us ACHD needs to complete the SIP ASAP. It might be work that ultimately isn’t necessary if air quality at least stays minimally compliant with the NAAQS, but we believe the best contingency plan is to remedy the contingency plan… before the next contingency plan. Regulatory word games aside, this all suggests some level of improvement in air quality over the years, which is mildly reassuring. But are we really out of the woods? Like we said, it’s all still a bit hazy. Editor's Note: For a deeper dive on the county’s PM2.5 “diet,” all the supporting materials for ACHD’s PM2.5 SIP are available online.

The Environmental Protection Agency (EPA) Monday officially proposed new rules intended to significantly reduce emissions of greenhouse gases (GHGs) and other harmful air pollutants from numerous oil and natural gas industry sources. In an earlier announcement addressing the proposal, the EPA stated the changes “would expand and strengthen emissions reduction requirements that are currently on the books for new, modified and reconstructed oil and natural gas sources, and would require states to reduce methane emissions from hundreds of thousands of existing sources nationwide for the first time.” This is great news. This is a great start. BUT TAKE NOTE: there are also great opportunities coming up VERY SOON for you to tell the EPA what you think about the new rules. On Nov. 16 – 18, the EPA will hold afternoon, half-day training sessions online to provide background information, an overview of the proposal, and other information on how to effectively engage in the regulatory process. The trainings are free and open to the public. Specifically, the audiences EPA hopes to engage in these training sessions are communities with environmental justice concerns, Tribes, and small-business stakeholders. You can read the original notice here. Sign up here. Once you’ve crossed that off your list – or even if you can’t make the trainings – consider speaking at public hearings scheduled to take place virtually Nov. 30, and Dec. 1. BUT AGAIN, time is limited: The last day to pre-register to speak at the hearings will be Nov. 24. It is possible there will be time to hear unregistered speakers in attendance but there is no guarantee. You can register to speak here. Alternatively, you can contact the EPA’s public hearing team by phone at (888) 372-8699 or by email at SPPDpublichearing@epa.gov. If you’re worried about what to say, the announcement webpage we mentioned above has a lot of great resources, among them is this advice: comments may address any aspect of the proposal, including: impacts you are experiencing related to pollution from the oil and gas industry; how you would like EPA to address your concerns; how EPA is addressing those concerns in the proposed rulemaking; and technical aspects of the proposal. If you can’t participate in any of the activities described above there is no need to worry: The EPA will consider written comments received on or before Jan. 14. More information on that process is available in the EPA’s Federal Register notice of the proposed rulemaking.

Stench returned to the Mon Valley. The likely culprit? Another day with sky-high concentrations of hydrogen sulfide (called H2S for short, an air pollutant known by its telltale rotten-egg odor) at the Allegheny County Health Department’s air quality monitors in both Liberty and North Braddock boroughs. Adding to the discomfort, levels of fine particulate pollution were elevated throughout the day, with AirNow.gov showing NowCast AQI values for the Liberty-Clairton as high as 152 – which the EPA classifies as unhealthy. While particulate pollution levels ended the day within federal guidelines, H2S levels at the North Braddock and Liberty monitors Wednesday exceeded Pennsylvania’s 24-hour average standard. By 9 a.m. today, another such exceedance was guaranteed at Liberty. That means there have been 45 such exceedances at the Liberty monitor and 17 more at North Braddock. “We’re still on pace to hit 50 exceedances by year’s end, which would double the total from 2020,” GASP Executive Director Patrick Campbell said. “GASP continues to be concerned not only with the number of exceedances that the Mon Valley has experienced, but also the physical impact air quality is having on residents.” He continued: “It’s well past time for the Allegheny County Health Department to provide the public with an update on what it is doing to get to the root of this problem. An enforcement action was levied against U.S. Steel back in April for violating the state’s H2S standard and since then there have been myriad exceedances but not one word from ACHD.” GASP is again – still – calling on ACHD to do right by the residents who deal with malodors all too often and to provide a public update on what’s causing the exceedances and what they are doing to stem them. “The total silence from ACHD speaks volumes to the people who bear the brunt of this pollution,” Campbell said. “Residents deserve better from the people charged with protecting our public health.”

Concentrations of the air pollutant known by its rotten-egg odor were high enough to exceed Pennsylvania’s 24-hour average of 0.005 ppm, ending the day at 0.008 ppm. This marks the 46th day of 2021 when H2S exceeded that standard at the Liberty monitor. There were 17 other such exceedances at ACHD’s air quality monitor in North Braddock Borough. “The Mon Valley remains on pace to hit at least 50 H2S exceedances by the end of the year. For those who might not know, that would double the amount from 2020,” GASP Executive Director Patrick Cambell said. “County leaders like to talk about how much our air quality has improved over the years, but in many areas, Allegheny County is failing to make improvements. This is one of them.” At this point, GASP has said it before in several dozen blogs this year but we’re going to keep saying it: Residents deserve more information and answers from the Allegheny County Health Department about what is causing the H2S issue and what it is doing to ensure that it stops. As a reminder: An enforcement action was levied against U.S. Steel back in April for violating the state’s H2S standard and since then there have been numerous exceedances but not one word from ACHD. “We’ve personally witnessed ACHD downplay and talk around the H2S issue at committee meetings,” Campbell said. “Where is their commitment to protecting the health of Allegheny County residents? It’s easy to discount something you don’t have to deal with personally.” He continued: “It’s well past time for the Allegheny County Health Department to provide the public with an update on what it is doing to get to the root of this problem. Editor’s Note: GASP staff charted and graphed H2S data for those who would like to take a deeper dive:

Photo courtesy of our friends at the Breathe Project. The Group Against Smog and Pollution (GASP) on Friday afternoon joined residents and fellow environmental advocates at a rally outside the U.S. Steel building in downtown Pittsburgh in advance of a meeting where U.S. Steel shareholders voted to approve the sale of the company to Nippon Steel. Our message was clear: Regardless of who is at the helm of the company, leadership must commit to a corporate future that prioritizes the public health of its neighbors in the Mon Valley and beyond - a future that marks an end to U.S. Steel’s legacy of pollution and community harm. Our Executive Director Patrick Campbell was among those who spoke at the rally. Here are his comments in case you missed it: Good afternoon. My name is Patrick Campbell, I am the executive director of the Group Against Smog and Pollution - or GASP- a nonprofit watchdog organization working to improve regional air quality since 1969. It’s so heartening to see so many of our neighbors literally bringing their own seats to the proverbial decision-making table today. The potential sale of the United States Steel Corporation to Japan-based Nippon Steel has been in the international spotlight for months. It’s been fodder for news outlets, trade associations, business analysts, and politicians. But every international story has hyper local impacts. Just ask some of the folks here with us today, many of whom are our neighbors living in the shadow of U.S. Steel’s Mon Valley Works facilities. They have worked for decades to hold the steelmaking giant accountable for the way its operations have fouled our air and marred our skyline. And that work continues today. So far this year, our local air quality regulators have already issued more than $2 million in civil penalties to U.S. Steel for emission-related violations in the Mon Valley. And the company has - and continues to - fight those enforcement actions through its army of corporate attorneys. It’s been well documented in court cases and media coverage that U.S. Steel has long maintained a “don’t buy, get by” mentality that favored band aid fixes at the Mon Valley Works to major operational upgrades. At nearly every turn here in Allegheny County, U.S. Steel has fought our health department’s attempts to get the Mon Valley Works back into compliance with air quality rules. Meanwhile, U.S. Steel held themselves up as consummate good neighbors in slick public relations campaigns and through strategic partnerships. We are here today to tell U.S. Steel and Nippon that any change in ownership needs to come with a change in company culture - one that truly prioritizes public health. Because at the epicenter of this potential multi-billion deal is a community of people who deserve better than what U.S. Steel has given them. At the center of this deal is a community with higher-than-average cancer risk and spiking childhood asthma rates thanks to our region’s chronic air pollution problem. At the heart of this deal are actual human beings who have suffered actual environmental harms because of U.S. Steel’s history of noncompliance with air quality rules. And we’re here today to let these shareholders know that no matter who is at the helm of the company, GASP will be watching and ready to use all our resources to hold polluters accountable. To let them know that we will continue to fight with - and for - neighborhoods in the Mon Valley and a clean air future for the region.

Councilperson Anita Prizio sponsored a proclamation celebrating Rachel’s commitment to GASP and the improvement of local air quality. It read: WHEREAS, after 20 years dedicated to Group Against Smog and Pollution (GASP), Rachel Filippini will depart from GASP to pursue the next chapter in her personal and professional life; and WHEREAS, GASP was founded in 1969 by volunteers concerned about air quality in southwestern Pennsylvania. Today, the organization continues to work to improve air quality in the region through education, advocacy, policy, and legal work; and WHEREAS, in 2001, Rachel joined GASP. She served the organization in various capacities such as, executive assistant, education coordinator, and executive director; and WHEREAS, Rachel has utilized knowledge obtained from her degree in Environmental Science from the University of Pittsburgh to spearhead Allegheny County air quality legislation, increase GASP’s educational work in local communities and schools, and continue to keep air pollution issues in the public eye; and WHEREAS, over the years, Rachel has received many accolades. In 2009, she was named one of Pittsburgh’s 40 under 40, and in 2011 one of the Women and Girls Foundation’s “Women Greening the Pittsburgh Region”; and WHEREAS, in 2017, Rachel was appointed to Allegheny County’s Air Pollution Control Advisory Committee; and NOW, THEREFORE, BE IT RESOLVED that I, Allegheny Council Member Anita Prizio, do hereby honor and recognize Rachel Filippini for her dedication to GASP and improving the air quality throughout southwestern Pennsylvania. IN WITNESS WHEREOF, I have hereunto caused the Seal of the County of Allegheny to be affixed this 28th day of September 2021. “It’s been an absolute honor to serve GASP for the past 20 years,” Rachel said in remarks before council, thanking members for the honor as well as their leadership on recent air quality issues like clean construction, permit fee schedule changes, and Mon Valley Air Pollution Episode regulations. Congrats, Rachel! In other air quality business, council on Tuesday referred to its appointment committee the re-appointment of these members of the Allegheny County Air Advisory Committee for terms expiring Dec. 31, 2023: Chip Babst Sara Marie Baldi Dan Bricmont Jeanne K. Clark Michael Corcoran Steve Hvozdovich Mark Jeffrey Bob Orchowski John Palmiere GASP wants to note: Rachel Filippini was a longtime member of the Air Advisory Committee and following her resignation began actively working to have our senior staff attorney and current Allegheny County regulation subcommittee member John Baillie take her place. We have sent letters to county officials and hope to have something to report back to you soon. We will keep you posted.