At a permit hearing Tuesday, GASP joined residents and advocates from Allegheny County Clean Air Now (ACCAN) and others to demand the Allegheny County Health Department (ACHD) ensure Neville Chemical’s Title V operating permit is as protective of public health as possible. As a reminder, Neville Township-based Neville Chemical is a manufacturer of hydrocarbon resins used extensively in the formulation of adhesive and sealants, concrete cure, coatings, inks, tire, and industrial rubber products. The facility has also been a significant source of stench for local residents and a subject of ACHD enforcement action in recent years. What kind of odor does a hydrocarbon resin manufacturer produce? Here's how our communications manager and longtime Neville Township resident Amanda Gillooly described it to us: "It's this pungent, chemical odor that makes your eyes water and your throat close up. On several occasions, I needed to use my rescue inhaler while stopped at the red light in front of the facility," she said. "It's really awful." While our senior attorney John Baillie pored over the details of Neville Chemical's Title V permit and provided formal technical comments that you can read here, GASP Executive Director Patrick Campbell presented these comments at the hearing: Good evening. My name is Patrick Campbell, I am the executive director of the Group Against Smog and Pollution - or GASP - a nonprofit organization advocating for improved air quality since 1969. Today, we are here to request the Allegheny County Health Department revise its draft Title V operating permit for Neville Chemical Co. to incorporate required “compliance certification, testing, monitoring, reporting and recordkeeping requirements sufficient to assure compliance with the terms and conditions of the permit.” After an exhaustive review of the draft permit, it is not clear how the testing, monitoring, recording, or reporting requirements are sufficient to assure compliance with various limits on PM emissions from the facility’s packaging operations. For example, at most, testing for some sources of emissions at the facility are required only once every five years, which is not sufficient to assure compliance with permitted limits. GASP has submitted formal technical comments that go into greater detail about those testing, monitoring, recording, and reporting requirements and how they are deficient- comments we hope ACHD heeds. Because residents in the Neville Island airshed need all the public health protections this Title V operating permit can provide. Living near industrial facilities like Neville Chemical impacts the health and quality of life for those on the island and beyond. When it comes to Neville Chemical, specifically, we’ve heard horror stories from one of GASP’s staff members about the noxious odors emanating from the plant. She told us she dreaded driving past while on her way to work and getting stuck at the red light outside the facility because on those occasions, the odor would make her eyes water and her throat close up. She told us and ACHD staff in complaints that more often than not, she needed to use her rescue inhaler - that’s how pungent the offsite odors were. We shouldn’t be hearing these types of stories on the outskirts of one of America’s Most Livable Cities, especially when ACHD has both the authority and tools to ensure Neville Chemical complies with air quality regulations through a more stringent Title V operating permit. Thank you.

The U.S. Environmental Protection Agency (EPA) today announced a rule to amend standards for facilities that use open burning and open detonation to treat waste explosives such as munitions, fireworks, flares or airbag propellants. If finalized, the rule would strengthen existing regulatory requirements to use safe and available alternative technologies to treat waste explosives and provide new technical standards for open burning and open detonation designed to better protect communities and military families from pollution. EPA also proposed a framework for permitting mobile treatment units aimed to expand potential treatment options for waste explosives and reduce the use of open burning and open detonation. "Open burning and open detonation of waste explosives like fireworks or munitions can have serious environmental and public health impacts, oftentimes in communities already overburdened by pollution," EPA Administrator Michael S. Regan said in a news release. "In close coordination with federal, state and local partners, EPA's proposal will work to better protect local communities from environmental and health harm while ensuring facilities are supported in the transition to new alternative technologies that safely manage explosive wastes." Explosive wastes include a range of items, including munitions, propellants, fireworks, and flares and are often treated by open burning and open detonation because historically, other safe modes of treatment have not been available. However, as described in 2019 reports by EPA and the National Academies of Sciences, Engineering, and Medicine, alternative technologies are now available to safely treat certain waste explosives. Unlike treatment of other hazardous waste, open burning and open detonation occurs in the open, and emissions are released directly into the environment. The proposed rule responds to community concerns, including the potential for exposure to pollutants released into the air, deposited into soil and surface water, and leached into groundwater after an open burning and open detonation event. Communities raised additional concerns about noise and vibration from facilities using open burning and open detonation to treat waste explosives. If finalized, the proposal is expected to reduce existing disproportionate and adverse impacts on communities with environmental justice concerns. Specifically, more frequent evaluations of alternatives to open burning and open detonation and new technical permitting standards for open burning and open detonation may accelerate the implementation of cleaner, safer alternative technologies. Now for a little bit of background: In 1980, due to the potential risks to human health and the environment, EPA prohibited open burning of hazardous waste under the Resource Conservation and Recovery Act (RCRA) with one exception for waste explosives "which cannot safely be disposed of through other modes of treatment." Since that time, facilities have been required to determine whether alternatives are safe and available. EPA committed to monitoring the progress of ongoing development of safe alternatives, as this explosives exception from the ban on open burning of hazardous waste was not intended to be indefinite. In developing this proposal, EPA engaged with Tribes, state regulators, communities, and operators of OB/OD facilities, including the Department of Defense, Department of Energy, and National Aeronautics and Space Administration. In June 2022, EPA also issued a policy memorandum to communicate existing requirements for open burning and open detonation facilities and to provide guidance to EPA Regions, states, and territories for permitting open burning and open detonation units under RCRA to protect human health and the environment. After publication in the Federal Register, EPA will take public comment for 60 days on the proposed rule. Review a prepublication copy of the proposed rule on our Revisions to Standards for the Open Burning / Open Detonation of Waste Explosives webpage. Learn about energetic hazardous waste. Editor’s Note: GASP staff is following this issue closely and will keep you posted as this process proceeds.

Our friends at Allegheny County Clean Air Now (ACCAN) have partnered with ROCIS (Reducing Outdoor Contaminants in Indoor Spaces) to provide residents in the Neville Island airshed with opportunities and resources to improve their indoor air quality. ROCIS’s online Low-Cost Monitoring program has cohorts that begin every few months and give residents the opportunity to understand and improve their indoor air quality and protect their family’s health. ACCAN wants to provide residents on and around Neville Island, especially those who suffer from health issues related to the industrial air pollution, access to resources, and information that can help protect themselves and their loved ones. “One of our staff members here at GASP tells us often about the noxious odors that she and her family experience, and about how it’s difficult to tell exactly what she is smelling and experiencing,” GASP Executive Director Patrick Campbell said. “We hope folks on Neville Island who have similar concerns about the air they are breathing will take advantage of the tools and resources at their disposal thanks to our friends at ACCAN and ROCIS.” Contact ACCAN at info@accan.org for more information about how the partnership between these two organizations can help your family monitor and improve the air quality in their home, often worsened by the industrial sources outside.

A few months back we blogged about the California Air Resources Board’s (also known as CARB) adoption of a regulation that would, over time, require the phase out of older, more polluting railroad locomotives to be replaced first with lower-emission locomotives and eventually with zero emission locomotives. CARB’s regulation could help reduce ozone and particulate matter pollution and improve air quality substantially in areas that are close to busy railroad tracks and freight yards, and generally reduce the railroad industry’s greenhouse gas emissions. The regulation would on its face be limited to locomotives operating in California but would have implications across the United States and beyond, because most locomotives do not stay in one state and may move anywhere within the continental United States, Canada, or Mexico.  Any locomotive that traveled into California would be subject to the regulation even if the locomotive mainly operated elsewhere. CARB’s regulation already faces a legal challenge from the railroad industry in a federal district court based in Sacramento. As we noted before, the industry claims that the regulation is inconsistent with the Clean Air Act, pre-empted by other federal statutes, and barred by the Interstate Commerce Clause of the United States Constitution. While that challenge winds its way through the courts, however, the U.S. Environmental Protection Agency (EPA) published a notice last week that it will hold a virtual public hearing and accept written comments on the discrete issue of whether CARB’s regulation meets the requirements for EPA authorization under Section 209 of the Clean Air Act – EPA is not empowered to determine whether the regulations may be inconsistent with or preempted by other federal statutes or the Constitution itself. Under Section 209, the states are generally barred from setting emission standards for nonroad engines or vehicles, but EPA may authorize such a standard established by California (only, not any other state) if three conditions are met: California’s determination that it needs the standard is not “arbitrary and capricious;” California needs the standard “to meet compelling and extraordinary conditions;” and the California standard “and accompanying enforcement procedures” are consistent with Section 209 Accordingly, EPA has requested that comments be limited to these issues: (a) whether CARB’s determination that its standards, in the aggregate, are at least as protective of public health and welfare as applicable federal standards is arbitrary and capricious; (b) whether California needs such standards to meet compelling and extraordinary conditions; and (c) whether California’s standards and accompanying enforcement procedures are consistent with section 209 of the Act. You can register to attend EPA’s virtual public hearing at:  https://www.epa.gov/regulations-emissions-vehicles-and-engines/virtual-public-hearing-californias-use-locomotive. You can submit written documents any time before March 24 at https://www.regulations.gov; identify your comments by Docket ID No. EPA-HQ-OAR-2023-0574.

The Allegheny County Health Department (ACHD) today fined U.S. Steel nearly $2 million for 362 pushing violations that occurred at its Clairton Coke Works facility between March 16, 2022, and Dec. 31, 2023. GASP staff is currently reviewing the Feb. 26 enforcement order, which we encourage you to read here. “We are in no way shocked by this news, and our neighbors in the Mon Valley probably aren’t, either” GASP Executive Director Patrick Campbell said. “U.S. Steel has been a bad neighbor for decades, and this is just the latest chapter in how the company continues to fail the communities in which it operates.” He continued: “As the order states, this is the eighth enforcement action ACHD has issued against U.S. Steel in just the past two years. That’s a pathetic record. Allegheny County residents - especially those in the Mon Valley - deserve better. We hope to continue to see vigorous enforcement when it comes to industrial bad actors like U.S. Steel.” Editor's Note: Check out this coverage from the Pittsburgh Tribune-Review's Justin Vellucci.

We recently blogged about the much-delayed implementation of the second round of Reasonably Available Control Technology (RACT II) determinations for three power plants in our region. If you read the blog post, you will recall that RACT II determinations are made to implement the 2008 revision to the National Ambient Air Quality Standard (NAAQS) for ozone by limiting emissions of the pollutants that form it, namely, oxides of nitrogen (NOx) and volatile organic compounds (VOCs). To hammer home the point of just how delayed those determinations are, we’re blogging today about a notice published Feb. 24 in the Pennsylvania Bulletin, in which the state Department of Environmental Protection (DEP) announced its preliminary RACT III determinations for 58 major sources of NOx and VOCs in Pennsylvania. Those RACT III determinations are to implement the 2015 revisions to the NAAQS for NOx. “That means - here in 2024 - that DEP is implementing a standard set in 2015 to protect the public health and welfare from high levels of ozone pollution before it has fully implemented the standard set in 2008,” GASP Senior Attorney John Baillie said. In an interesting twist, the 58 RACT III determinations that DEP noticed this week are all for sources for which DEP found that by complying with emission limits set for RACT II, the sources also satisfy RACT III. For many of these sources, DEP’s RACT II determinations took so long to make that the operating measures and technologies for controlling ozone-forming pollution did not change before it made its RACT III determinations. There are eight sources in Allegheny County among the 58 listed in DEP’s Feb. 24 notice: ATI Flat Rolled Products in Brackenridge the North Shore Energy Center in Pittsburgh Neville Chemical Company on Neville Island Pittsburgh Allegheny County Thermal in Pittsburgh Synthomer Resins (formerly Eastman Chemical) in Jefferson Hills U.S. Steel Clairton Works U.S. Steel Edgar Thomson Works in Braddock and U.S. Steel Irvin Works in West Mifflin It is likely that for those sources, no changes to emission limits will be made as a result of RACT III. DEP’s work on RACT will continue in the coming months; there are still many sources for which RACT III determinations have not been made. We will keep you posted on new developments as they occur.

The Pittsburgh Foundation’s amazing Day of Giving is this Wednesday, October 3. Donations given on this day will be added to by the Pittsburgh Foundation from a pool of $750,000. Learn more by clicking here. Your gift will allow us to continue reducing diesel pollution in the region.  GASP helped lead the effort which culminated in the City of Pittsburgh’s passage of Clean Construction legislation. The law requires developers working on large projects receiving at least $250K in public subsidies to use some portion of cleaner diesel construction equipment on the job. We also collaborated with UPMC and PNC to pass clean construction policies at their institutions. Financial support lets us keep reviewing air permits for Allegheny County and beyond.  Recent work has led to lower levels of manganese emissions from a rail parts manufacturer and less NOx and VOCs from Marcellus compressor stations. How will your charitable giving help us improve local air quality? Your donation gives us the resources to use air monitors at homes where odors and emissions from wood-burning or shale gas drilling are a concern, to train citizen Smoke Readers to make smoke-stack observations, and to track particulate matter levels from bicycle-mounted air monitors. Please, visit pittsburghgives.org  to learn more about this exciting opportunity, and support GASP’s efforts to combat air pollution to improve regional air quality this Day of Giving.

Last week, GASP joined the National Wildlife Federation (NWF) and several other local groups as NWF released their latest report, “Ruined Summer: How Climate Change Scorched the Nation in 2012.” The report examines those climate change impacts whose harms are acutely felt in the summer. Heatwaves; warming rivers, lakes, and streams; floods; droughts; wildfires; and insect and pest infestations are problems we are dealing with this summer and are likely to face in future summers. GASP spoke about the link between hotter summers and worsening air quality. This summer’s hot temperatures have been especially difficult for asthma sufferers and those with cardiovascular disease. We have had the perfect recipe for creating one particular type of air pollution: ground-level ozone. Ground-level ozone is plentiful when its ingredients (including volatile organic compounds, carbon monoxide, and nitrogen oxides coming from motor vehicles and industrial emissions) combined with sunny, hot days with little air movement. So far, in Allegheny County, we’ve had 20 days in 2012 in which the ozone level exceeded the national standard of 75 parts per billion. And we still have another month to go in our ozone season. There were only 12 exceedance days recorded in Allegheny County in 2011. When ozone comes into contact with living tissue like your lungs it attacks and damages the cells lining the airways, causing swelling and inflammation. Some have compared ozone’s effect to sunburn inside your lungs. While children, the elderly, and those with respiratory and cardiovascular disease are the most vulnerable to air pollution such as ozone, all people, even young and fit athletes, are susceptible to ozone’s negative effects. People that exercise outdoors have elevated risk because the longer and more intense the workout, the higher the ozone dose delivered to the lungs. This leads to higher risk of a decrease in lung function, the onset of lung inflammation, and the risk that their athletic performance will be impaired. Continued global warming could make it even more difficult to meet the ground-level ozone standards in the future. In addition to weather patterns being more favorable to ozone formation, some emissions of ozone precursors are expected to increase as the demand for air conditioning and the risk of wildfires increase, and as high temperatures cause more VOCs to offgas into the air. Global warming will make it that much more challenging for cities like Pittsburgh, which already struggles with air pollution, to reduce ozone. The time is now to reduce carbon pollution and to protect and enforce the Clean Air Act. Last week’s news that our vehicle fleet in the U.S. will get much cleaner in the next few decades was great to hear, but the new regulation only addresses a portion of the problem. Threats to our air quality come from many sources, from the tailpipe of a diesel truck, to the smoke stack of a local coal-fired power plant, to the compressor engine at a natural gas drilling operation. The push for improved air quality can’t come from environmentalists alone. Policymakers, industry, and individuals all have important roles to play in improving our region’s and our nation’s air quality. What are some things that we can do locally? • Curb diesel emissions, by ensuring that publicly subsidized projects in the city implement clean construction legislation. The black carbon in diesel emissions directly absorbs incoming solar heat and is a potent greenhouse gas. • ALCOSAN should work with the EPA and municipal and community leaders to add green solutions to the plan for fixing the sewers, which will benefit air quality. • The natural gas industry should take steps to minimize emissions from its operations, many of which are not only toxic on their own but are also greenhouse gases.

Learn about GASPʼs recent victories and current projects. Meet GASP staff, board, members, and others who care about improving our regionʼs air quality.  View a recently discovered short film from the 1970s and cartoons (featuring Dirty Gertie, below) which depict the fight against air pollution in Pittsburgh.  Enjoy refreshing beverages and yummy hors dʼoeuvres. This event is for everyone, from long-time friends of GASP to people who want to make their first connection with us. FREE and open to the public, but please RSVP to jamin@gasp-pgh.org. GASP Open House Thursday, July 19 5:30 p.m. – 7:30 p.m. 5135 Penn Avenue Pittsburgh, PA 15224

Imagine: Pittsburgh’s beautiful skyline, cyclists whizzing by on a trail, and you, all on the nightly news! GASP needs you to come to a press event on Monday, July 16th, to show support for better air quality for our region (and the whole country). In June, the EPA proposed to strengthen the National Ambient Air Quality Standard (NAAQS) for PM2.5 by setting the annual standard at a level within the range of 12-13 micrograms per cubic meter. EPA proposes to retain the daily standard at 35ug/m3. The EPA is currently accepting comments on the proposed rule through August 31, 2012 and a hearing is being held in Philadelphia on July 17th. To sufficiently protect those most at-risk–children, teens, seniors, people with chronic lung diseases like asthma, people with cardiovascular disease, and people who work or exercise outdoors—we are calling upon EPA to set an annual standard of 11 micrograms per cubic meter (11ug/m3) and a daily standard of 25ug/m3. This is in line with many in the scientific, medical, and environmental community such as the American Lung Association, American Heart Association, American Thoracic Society, Clean Air Task Force, and Earthjustice. But we can’t do it alone. We’re looking for you to join us as we explain this to the media.  The more people in the frame, the better! Come in your regular clothes or dressed in an outfit from your sport of choice–cyclists’ spandex, skateboard pads, running gear, or whatever you’d like. All participants will get a FREE Athletes United T-shirt, in white or charcoal. Please contact Jamin via email or at (412) 924-0604 for information and to let us know if you can join us in standing up for better air quality. noon on Monday, July 16 Trail/parking lot behind Riverwalk Corporate Centre (old Terminal Building), South Side, Pittsburgh