The Group Against Smog and Pollution (GASP) is seeking Allegheny County students in grades 9, 10, and 11 interested in becoming environmental game-changers. If that sounds like you or someone you know, we invite you to apply today for an innovative program called Fresh Voices for Clean Air. For the third year, GASP is partnering with Greater-Birmingham Alliance to Stop Pollution (GASP), a non-profit organization working in the greater Birmingham area in Alabama to advance healthy air and environmental justice through education, advocacy, and organizing. “Our missions are very similar - they work to reduce air pollution, educate people about the health risks associated with unhealthy air quality, and encourage municipal leaders to be role models for clean air and clean energy development,” Patrick Campbell said. “We’re excited for another opportunity to partner with our friends in Birmingham and look forward to seeing what the students come up with this time around.” Here’s how Fresh Voices for Clean Air works: GASP will pair a small group of high school students in Allegheny County with a group of their peers in Birmingham, Ala. for a school year-long collaborative partnership. Throughout 2023-24, the cohorts in each city will meet virtually to participate in discussions with each other as well as guest speakers. This year, Fresh Voices will be partnering closely with Communitopia’s Pittsburgh Youth for Climate Action (PYCA). The team will learn more about air quality while building the skills necessary to become effective environmental advocates. By the program’s end, students will have created, developed, and executed an air quality project of their own choosing, with the support of adult mentors in Pittsburgh and Birmingham. “This new partnership between air quality-focused non-profit organizations in Pittsburgh and Birmingham reflects our cities’ similar industrial and environmental history,” said Michael Hansen, executive director of the Greater-Birmingham Alliance to Stop Pollution. “A century ago, Birmingham was nicknamed the ‘Pittsburgh of the South.’ The two cities have experienced some of the worst air quality in the nation, and residents have been fighting back for decades.” GASP Air Quality Educator Laura Kuster agreed: “Discovering and discussing the similarities and differences between experiences in these two regions will be a key component of the collaboration,” she said. The program will run through the 2023-24 academic year and is open to students in grades 9, 10, and 11 who attend school in either Allegheny County or Jefferson County, Ala. Students must be willing and able to participate in Fresh Voices for Clean Air until the end of the school year in June 2024 to be considered. Participants will need access to a laptop or desktop computer, tablet, or smartphone to take part in virtual meetings, as well as written consent from a parent or guardian. The deadline to apply is Sept. 22. You can apply here. Need a little more info first? GASP will host a brief virtual info session via Zoom at 4:30 p.m. Sept. 12. GASP staff will provide details about the program and answer any questions. You can register here. The Fresh Voices for Clean Air initiative was made possible by funding through the Grable Foundation. The Group Against Smog and Pollution (GASP), a non-profit founded in 1969, works to improve air quality in SWPA to safeguard human, environmental, and economic health. GASP is a diligent watchdog, educator, litigator, and policy-maker on air quality issues impacting our region. Greater-Birmingham Alliance to Stop Pollution (GASP), a non-profit organization working in the greater-Birmingham area in Alabama, advances healthy air & environmental justice through education, advocacy, and organizing. They strive to reduce air pollution, educate the public on the health risks associated with poor air quality, and encourage community leaders to serve as role models for clean air and clean energy development. Communitopia is a nonprofit organization working to provide transformative climate change education that develops today’s climate leaders and advances equitable solutions. They envision a world where solution-based climate change education has transformed community thought and practice resulting in empowered and healthy local communities.

The U.S. Environmental Protection Agency (EPA) this summer proposed policy revisions that will impact coke-making operations, including those at U.S. Steel’s Clairton Coke Works and Cleveland Cliffs’ coke ovens in Monessen. We’re here to break down these proposed new National Emission Standards for Hazardous Air Pollutants (or NESHAPs for short). Spoiler: The proposed revisions unfortunately offer much less than they could. Some Necessary Background As we reported last week, the Clean Air Act requires EPA to review NESHAPs for a particular category of sources eight years after it promulgates them. This review must confirm that the emissions permitted under the NESHAPs do not create an unacceptable health risk (this is what’s known as a residual risk review). In this context, an unacceptable health risk means that emissions of hazardous air pollutants (HAPs) from the source category at any one facility are likely to cause more than 10 deaths or serious illnesses among 1 million people with lifetime exposure to those HAP emissions. Still with us? Good. Next, EPA must determine whether control technologies have become available that could be used to reduce emissions of hazardous air pollutants from the source category (this is called the technology review). The Clean Air Act requires EPA to perform a technology review for each NESHAPs every eight years. However, EPA has taken the position that the Act requires it to perform only one residual risk review for each NESHAPs, eight years after a particular NESHAPs is first promulgated. There are technically two sets of NESHAPs for coke manufacturing facilities, with each covering different sources within those facilities: First, the NESHAPs for Coke Oven Batteries were promulgated in 1993 and revised in 2005 after a residual risk and technology review. Second, the NESHAPs for Coke Ovens: Pushing, Quenching, and Battery Stacks were promulgated in 2003. The proposed revisions EPA published on Aug. 16 cover both sets of NESHAPs and are thus based on the findings from the agency’s second technology review of the NESHAPs for Coke Oven Batteries and the first residual risk and technology review of the NESHAPs for Coke Ovens: Pushing, Quenching, and Battery Stacks. As a result of those reviews, EPA has proposed three notable revisions to the NESHAPs, which are of varying significance in relation to the coke plants in Clairton and Monessen. Three Revisions That Could Most Impact Clairton, Monessen Mills First, EPA will require all coke-making facilities to monitor benzene concentrations at four spots along their fencelines. The monitors would be required to operate continuously and report benzene concentrations averaged over two-week-long periods. Here’s how it would work: If a monitor detects benzene levels that are more than 3 micrograms/cubic meter higher than established background levels (AKA the ambient level of pollution that is not affected by local sources of pollution), the facility must conduct a root cause analysis and take corrective action. If a facility’s monitors detect low levels of benzene, it will be permitted to sample on a less frequent basis. Second, EPA will reduce the percentages of leaking coke oven doors, lids, and offtakes that are allowable under the NESHAPs, with the new limits being dependent upon the facility - the Clairton Coke Works will have stricter limits than all other facilities in the United States. The limits that apply will also depend on the type of coke oven door – at Clairton, the allowable percentage of leaking coke oven doors will be higher for tall doors, while at all other facilities, those allowable percentages will be the same for both types of door. “Although lower limits on leaking equipment are to be welcomed, it is difficult to predict how much pollution they will actually prevent because coke oven facilities regularly violate the higher, existing limits on such leaks and also to determine how much pollution equipment leaks actually create when they do occur,” GASP senior attorney John Baillie explained. Third, EPA will establish emission limits for six HAPs from battery stacks at by-product recovery coke plants (which includes both Clairton and Monessen) for which no such limits currently exist. The six HAPs are hydrogen chloride, hydrogen fluoride, hydrogen cyanide, mercury, and metallic HAPs. “It does not appear that these new limits will require either facility to add new controls or make changes to its operations; rather, the limits quantify allowable HAP emissions that have been occurring and will continue to occur,” Baillie said. He continued: “EPA did not perform a second residual risk review of the Coke Oven Batteries NESHAPs in connection with the proposed revisions it published on August 16. Which is too bad. If it had, additional emission or operating limits that save lives might be in the pipeline.” In the residual risk review that EPA did perform for the Coke Oven Batteries: Pushing, Quenching, and Battery Stacks NESHAPs, EPA determined that although HAP emissions from pushing, quenching, and battery stacks at coke ovens do not pose an unacceptable risk under the existing NESHAPs, actual facility-wide emissions from coke ovens do: [the maximum cancer risk posed by all sources of HAP at coke oven facilities] would remain unchanged, at 50-in-1 million because the whole facility [maximum individual risk] is driven by the estimated actual current fugitive emissions from coke oven doors … and we do not expect reductions of the actual emissions from doors as a result of this proposed rule. “A risk level of 50-in-1 million exceeds EPA’s acceptable risk level by a whopping factor of five,” Baillie said, “EPA is failing the communities it has a duty to protect by not imposing stricter emission limits or operating requirements.” EPA will accept comments on the proposed revisions through Oct. 23. Editor’s Note: Stay tuned, GASP is preparing sample comments so folks can easily weigh in on these important revisions.

If you’ve noticed a distinctive stank in and around the Mon Valley over the past week, Allegheny County Health Department (ACHD) air quality monitor data show a likely culprit: Hydrogen sulfide (H2S) concentrations that exceed Pennsylvania’s 24-hour standard. SmellPGH users certainly noticed: Many reports poured in those days with folks complaining of an industrial, rotten-egg odor. Our Mon Valley friends (and those who live downwind of those communities) know the H2S stench all too well: So many people have told us so many times that the rotten-egg odor is strong enough to seep through their closed windows and pungent enough to wake them from slumber. If you’re asking yourself, “What’s the source of all that stink?” we’d like to remind folks: In 2022 ACHD published a comprehensive study analyzing potential sources of H2S that have been driving exceedances of the Pennsylvania 24-hour average H2S standard at its air quality monitor in Liberty Borough. The 31-page study concluded: “Based on all available data and resources, H2S exceedances that occurred at the Liberty site during the period of Jan. 1, 2020, through March 1, 2022, can be attributed entirely to emissions originating at U.S. Steel’s Clairton coking facility.” But it should be noted: The Clairton Coke Works isn’t the *only* industrial source of the foul-smelling air pollutant - U.S. Steel’s Edgar Thomson facility in North Braddock is one, too. Now back to recent conditions, because this past week has been a rough one: ACHD monitor data show that H2S concentrations exceeded the state limit this past Saturday, Sunday, and Monday at its air quality monitor in Liberty Borough and on Monday and Tuesday at the North Braddock location. For those keeping count, that means there have been 58 such exceedances at the Liberty monitor so far this year and 21 more at the North Braddock monitoring station. Note: ACHD began monitoring for H2S at the North Braddock monitoring location in 2020. “Based on the rate of exceedances so far this year, we are on pace for 90 H2S exceedances at Liberty and 32 at North Braddock for 2023. If that pans out, that would make 2023’s numbers slightly better than 2021 but clearly worse than 2022,” GASP Executive Director Patrick Campbell said. “Because the provisions in the consent decree between ACHD and U.S. Steel were expected to stem these emissions issues, we have to ask: Why the sharp increase in H2S exceedances at the North Braddock monitor?” Editor’s Note: A little context: The consent decree called for U.S. Steel to begin “feeding an oxidizing chemical additive or additives…into the slag pit quench water spray system, to enhance suppression of H2S emissions.” Stay tuned, GASP is investigating how - and if - U.S. Steel met the requirements of the agreement.

The Environmental Protection Agency (EPA) this week announced a new review of the Ozone National Ambient Air Quality Standards (NAAQS) to ensure the standards reflect the most current, relevant science and protect people's health from these harmful pollutants. EPA Administrator Michael Regan said in a release that the department reached this decision after carefully considering advice provided by the independent Clean Air Scientific Advisory Committee (CASAC). Little bit of background: In October 2021, EPA announced a reconsideration of the previous administration's decision to retain the NAAQS for ozone. EPA is incorporating the ongoing reconsideration into the review announced today and will consider the advice and recommendations of the CASAC in that review. “The Agency will move swiftly to execute this new review of the underlying science and the standards – prioritizing transparency, scientific integrity, inclusive public engagement, and environmental justice,” it said in the release. Exposure to ground-level ozone can cause respiratory issues, aggravate asthma and other lung diseases, and may lead to missed days of work or school, emergency room visits, and premature deaths. These costly public health impacts can be especially harmful to children and older adults, disproportionately affecting people of color, families with low incomes, and other vulnerable populations. Nationally, due in part to strong EPA emission standards that reduce air pollution, ozone air quality is improving. Between 2010 and 2022, national average ozone air quality concentrations have dropped 7 percent. In many of the areas designated as not meeting the current 2015 standards, work remains. To continue progress in reducing ozone, EPA has initiated important regulatory actions including strong new federal emissions standards for cars and trucks and strengthening rules to reduce pollution from the oil and natural gas industry – a leading source of ozone-forming volatile organic compounds. Taken together, the projected benefits of these and other actions addressing industrial and power sector emissions, such as with the Good Neighbor Plan, would cut emissions of ozone precursors by hundreds of thousands of tons with estimated health benefits adding up to billions of dollars. The new review will allow EPA to consider fully the information about the latest ozone science and potential implications for the ozone NAAQS provided by the CASAC and the Ozone Review Panel. EPA will conduct the review according to well-established best practices and processes that embrace scientific integrity and the role of the public to provide input at multiple steps along the way. Concrete, transparent, and public next steps include: Issuing a call for information in the Federal Register in the next few days; convening a public science and policy workshop in spring 2024 to gather input from the scientific community and the public; in the summer 2024, EPA will summarize the proceedings of the workshop to consider how the information gathered can be used to inform the next review, including specific areas of science that warrant particular focus and analytic enhancements; in fall 2024 the agency plans to release its Integrated Review Plan, Volume 2 to guide CASAC consideration and development of the Integrated Science Assessment. EPA established the current standards at a level of 70 parts per billion in 2015 and retained them in 2020, after concluding that there was little new information to suggest the need for revision. The CASAC, however, has identified studies published more recently and also recommended that EPA conduct additional risk analyses that might support more stringent standards. EPA has determined that incorporating the ongoing reconsideration into a new review will best ensure full consideration of this new information and advice. Editor’s Note: Get more info about ground-level ozone and the most recent review of the ozone NAAQS here.

Self-care is defined as “caring for oneself through practices that promote health and active management of illness when it strikes.” Did you know that TODAY is Internet Self-Care Day? (Yes, it’s really a thing). This holiday of sorts is celebrated each Aug. 21 and is dedicated to encouraging folks to use the internet to find resources to help take care of themselves. GASP is here to remind you on this glorious day that self-care is more than just making time for a facial or workout (although we are all in for those, too!) - it’s also about making healthy choices. …like understanding local air quality, how it impacts your health, and how you can take action to mitigate your exposure when conditions are - or are expected to be - poor. To help make your air-related self-care a little easier, we created this Air Quality Self-Care Checklist for you. Check it out and check 'em off as you complete them!

New limits on hazardous air pollution are on the way for one of the largest industrial polluters in our region - the Environmental Protection Agency (EPA) has proposed revisions to the National Emissions Standards for Hazardous Air Pollutants (NESHAPs) for Integrated Iron and Steel Manufacturing Facilities. U.S. Steel’s Edgar Thomson Works in Braddock is a major source of emissions of metallic hazardous air pollutants (HAPs) and is one of only nine facilities in the United States subject to the NESHAPs for Integrated Iron and Steel Manufacturing Facilities. A little background on why this is all happening: Under section 112 of the Clean Air Act, EPA must determine the categories of sources whose emissions of HAPs endanger public health and set standards for those emissions (namely, the NESHAPs). After EPA establishes a NESHAP for a particular source category, it is required to review the NESHAP every eight years and revise the NESHAP as necessary to protect public health, prevent an adverse environmental effect, or account for improvements in work practices or control technologies that affect HAP emissions. The NESHAPs for Integrated Iron and Steel Manufacturing facilities were developed in 2003 and are codified as at 40 C.F.R. §§ 63.7780 - 7852. On July 31, EPA published proposed revisions to the NESHAPs for Integrated Iron and Steel Manufacturing Facilities which will cap off a 20-year-long (and yet ongoing) review that the Clean Air Act gives EPA eight years to complete. The proposed revisions will impose new emission standards and limitations that are focused on reduced fugitive emissions of metallic HAPs from integrated iron and steel manufacturing facilities as follows: New work practice requirements to prevent unplanned blast furnace bleeder valve openings and a limit of no more than five such openings per furnace per year; New opacity limits on visible emissions from planned blast furnace bleeder valve openings; New opacity limits on visible emissions from slag pits and slag handling, storage, and processing operations; New opacity limits on visible emissions from blast furnace bell leaks, and new work practice requirements aimed at preventing such leaks; New work practice requirements aimed at reducing fugitive emissions from “beaching” iron from blast furnaces; and New opacity limits on visible fugitive emissions from basic oxygen process furnace shops and blast furnace casthouses, and new work practice requirements aimed at reducing such emissions. Except for opacity limits on visible emissions from basic oxygen process furnace shops and blast furnace cast houses, the fugitive emissions addressed by the proposed revisions are not currently regulated by the NESHAPs for Integrated Iron and Steel Manufacturing Facilities. EPA also proposes to require that each integrated iron and steel manufacturing facility install four fence line monitors to detect fugitive emissions of chromium (which will serve as a proxy for all fugitive emissions of all metallic HAPs) and to take action to reduce such emissions if monitored levels exceed a yet-to-be-established threshold that will not exceed one microgram of chromium per cubic meter (1 µg/m3). EPA estimates that once implemented, the measures required by the proposed revisions will reduce emissions of HAPs from the integrated iron and steel manufacturing sector by 79 tons per year, at a total sector-wide cost of $2.8 million. Note: EPA did not break down expected emission reductions on a facility-by-facility basis. EPA held a public hearing on the proposed revisions on Tuesday, but will accept written comments on them through Sept. 14. “New limits on hazardous air pollution are on the way for U.S. Steel’s Edgar Thomson Work, one of the largest polluters in our region,” GASP Senior Attorney John Baillie said. “By tightening emission limitations on large steel mills EPA continues to slowly make the air around big industrial facilities less dangerous to breathe.” EPA is seeking comments on the technical aspects of the proposed revisions; comments may be submitted by mail or electronically: Federal eRulemaking Portal: https://www.regulations.gov/. Follow the online instructions for submitting comments. Email: a-and-r-docket@epa.gov. Include Docket ID No. EPA–HQ–OAR– 2002–0083 in the subject line of the message. Mail: U.S. Environmental Protection Agency, EPA Docket Center, Docket ID No. EPA–HQ–OAR–2002– 0083, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460. Comments should reference Docket ID No. EPA–HQ– OAR–2002–0083.

On a beautiful August Thursday in Bellevue, the sounds of nature abounded - birds chirped, insects buzzed, and a gentle wind sent a shiver through a tapestry of trees overlooking the Ohio River and the industrial facilities perched on its bank. Chief among them is the Metallico recycling operation on Neville Island, a facility that’s long been known for belching thick plumes of smoke, periodic explosions, noxious odors, and dust migration issues. As morning melted into afternoon, the clanging of machinery and the roar of the facility’s shredder increasingly drowned out those nature noises. The racket was so loud that GASP’s longtime program manager Sue Seppi needed to raise her voice to welcome the folks assembled to learn more about the science of smoke reading. For those who might have never heard of it: Smoke reading is a general term for people trained and certified to recognize and understand visible emissions from sources such as smokestacks, what violations look like, and how to make effective air quality reports. Those in attendance - which included members of Allegheny County Clean Air Now (ACCAN), Valley Clean Air Now (VCAN), and students from the University of Pittsburgh - gathered around to get the skinny on how to be even more effective air quality watchdogs through analyzing those neighborhood plumes. With clipboards and educational materials in hand, Sue led the group through a general overview of Method 9 - where to stand when making observations, how to properly analyze plumes and distinguish emissions from steam, and when to make reports to local air quality regulators when their readings show a possible violation. As it turned out, those in attendance were quick learners: Within just a few readings, participants were shouting out the correct opacity readings for milky Metallico plumes. “It was a great afternoon to learn more about Metallico’s operations and see - and hear -firsthand how the facility’s operations impact the everyday lives of residents who live nearby,” GASP communications manager and longtime Neville Island resident Amanda Gillooly said. “As a resident, there are other polluters on my radar and I look forward to using what I learned to help me make better complaints to the Allegheny County Health Department when they literally raise a stink.” Sue said “it made her day” when one of the Pitt student attendees decided to apply for a free spot to attend Smoke School coming up in late September (for those who may not know: the Allegheny County Health Department sponsors a small number of residents to attend the training). Stay tuned - more on *that* coming this fall! Editor’s Note: This most recent smoke reading workshop was the second of four planned as part of a GASP watchdog tour of Allegheny County. Stay tuned - we might be coming to evaluate a plume near you.

The term island living may invoke images of clear water, sun-splashed beaches, and warm, gentle breezes for some. Unfortunately, our friends on Neville Island (and surrounding areas - we’re looking at you Bellvue, Ben Avon, and McKees Rocks!) have reported very different conditions. They’ve told us about noxious odors near Neville Chemical. They’ve told us about explosions at Metalico (and we all know about the high-profile fire back in 2021) and the smoky, stinky plumes that sometimes emanate from the metal recycling facility. “It’s pretty crazy when you think about all the sources of air pollution in our small, island community,” GASP communications manager and longtime Neville Island resident Amanda Gillooly said. “Even the Allegheny County Health Department has noted that air pollution in the Neville Island airshed is a major concern.” That’s why she hopes her neighbors - and anyone interested in learning more about hyperlocal air pollution issues - will join GASP at 10:30 a.m. Aug. 3 to get a crash course on Neville Island air pollution sources, how emissions can impact your family’s health, how to make effective air quality complaints, and how to evaluate industrial plumes with visible emissions observation aka smoke reading. Some logistical details: We will meet at the Community Presbyterian Church of Ben Avon, 7501 Church Avenue, Ben Avon, PA, 15202 in the parking lot off of Rostrevor Place. We will then transport attendees to a nearby viewing location for some smoke reading. Our friends at Allegheny County Clean Air Now will also be on hand to provide history, background information, and context. Bring a clipboard, pen, and watch with a second hand if possible (your cell phone could work, too). RSVP here. Questions? Email sue@gasp-pgh.org. Editor’s Note: Our first smoke reading stop was in Clairton. You can check that out here.

FOR IMMEDIATE RELEASE GASP, Residents to Hold Press Conference Telling ACHD: Revise Coke Oven Regs & Get a Handle on H2S Violations PITTSBURGH – The Group Against Smog and Pollution (GASP) will hold a press conference at 11:30 a.m. Wednesday, Nov. 6 at the portico of the Pittsburgh City-County Building to tell the Allegheny County Health Department (ACHD): Enough is enough with ongoing violations of the hydrogen sulfide (H2S) standard—it’s time to strengthen our local coke oven regulations. At the event press conference, local residents impacted by poor air quality and fellow environmental activists will join GASP in calling on the Allegheny County Health Department to do what it promised more than a year ago: Revise coke oven regulations that would help reduce hydrogen sulfide, which is often associated by a tell-tale rotten egg stench. Speakers will include: GASP Executive Director Rachel Filippini Mark Dixon, local activist and filmmaker Edith Abeyta, resident of North Braddock Jonathan Reyes, resident of East Pittsburgh Christine Graziano, resident of Shadyside Jay Walker, a community organizer with Clean Air Council GASP will then be presenting an associated petition with more than 500 signatures to the Allegheny County Board of Health, which meets at 12:30 p.m. the same day. “More stringent coke-oven regulations are important because coke-making is a primary source of H2S in Allegheny County. In fact, U.S. Steel’s Clairton Coke Works is the largest emitter of H2S in the entire state,” GASP Executive Director Rachel Filippini said. According to statistics self-reported from U.S. Steel and published on the Department of Environmental Protection eFacts website, Clairton Coke Works emitted 109 tons H2S in 2017, which are the latest statistics available. “To put that into perspective: All other self-reported emissions combined for all sources in the entire state of Pennsylvania were only 59 tons,” she added. While most smelly, airborne chemicals have no regulatory concentrations, hydrogen sulfide does. In Allegheny County there is a limit for hydrogen sulfide, which is monitored by ACHD. On average, that standard has been violated about 50 times a year for the past several years—and twice last month, according to preliminary data. “How many tens of thousands of odor complaints need to be submitted by countless residents before local officials do what is necessary to fix this most-unnecessary offense in this otherwise most-livable city?” Dixon said.  “And why has the number of SmellPGH complaints continued to rise even after US Steel announced that their post-fire repairs at Clairton Coke Works were completed?” GASP is a nonprofit citizens’ group in Southwestern PA working for a healthy, sustainable environment. Founded in 1969, GASP has been a diligent watchdog, educator, litigator, and policy-maker on environmental issues, with a focus on air quality in the Pittsburgh region. Media Contact: Amanda Gillooly Communications Manager Group Against Smog and Pollution (GASP) amanda@gasp-pgh.org/ 412-924-0604 ### #HydrogenSulfideStandard #cokeovenregulations #EdithAbeyta #MarkDixon #hydrogensulfide #ChristineGraziano #RachelFilippini #emissions #AlleghenyCountyHealthDepartment #JonathanReyes #ACHD #airquality

The U.S. Environmental Protection Agency announced its decision to list benzene as a hazardous air pollutant under Section 112 of the Clean Air Act on June 8, 1977, based on reports “strongly suggest(ing) an increased incidence of leukemia in humans exposed to benzene.” Despite more than 40 years of regulations and research highlighting the danger of exposure to benzene, EPA’s Toxic Release Inventory data show U.S. Steel’s Clairton Coke facility was still able to emit over 30,000 pounds of this toxic pollutant in 2018, making it far and away the largest stationary source in Allegheny County. While raw benzene emissions are down significantly from the levels first reported in the 1970s and ‘80s, risks remain. Levels of benzene in the ambient air measured just outside South Allegheny High School–the location of the Allegheny County Health Department’s Liberty Monitor–suggest public health could be at risk. U.S. Steel must begin working with the Allegheny County Health Department (ACHD) to increase monitoring and reduce emissions. In May of 2018—months before a fire at U.S. Steel’s Clairton Coke Works knocked out crucial pollution control systems at the facility—ACHD officials announced at a Board of Health meeting that they were planning to revise the county’s pollution control regulations covering coke oven emissions. GASP supported the plan and expected tougher regulations would lead to reduced benzene emissions from the coke facility, as well as reductions in emissions of fine particulate matter (PM2.5) and other gasses such as hydrogen sulfide (H2S). In fact, GASP just this month held a press conference calling on ACHD to do what it promised all those months ago—and even presented a petition with the signatures of nearly 650 people imploring the county to get a handle on the tell-tale rotten egg odor caused by H2S emissions. Meanwhile, a series of enforcement orders issued by ACHD to U.S. Steel starting in the second half of 2018 appeared to confirm the notion that tougher measures were needed to protect local communities from coke oven emissions. Addressing air quality in an interview after issuing one of those orders, ACHD Deputy Director of Environmental Health Jim Kelly told reporters that “following decades of decline, the Liberty monitor’s PM2.5 readings began increasing in 2014, primarily due to fugitive emissions from the Coke Works.” Kelly also noted that those “fugitive emissions” – untreated emissions that do not come from a smokestack – are composed of a number of hazardous and cancer-causing air pollutants, including benzene, toluene, and ethylbenzene. He admitted that benzene emissions in particular were “very significant,” and “something we should be concerned about.” Shortly after this interview, a fire on Christmas Eve at the Clairton Coke Works and its aftermath shifted ACHD’s focus away from regulatory reform and toward more pressing issues associated with increased emissions from the plant. Now that operations at the Clairton facility appear to be back to normal, GASP investigated the state of the regulatory revisions proposed more than a year and a half ago, as well as data quantifying the impact of coke oven emissions. First, the good news: While there is no EPA requirement to monitor benzene near coke facilities, ACHD—to its credit—does so at its Liberty Monitor site, which is a little over a mile northwest of, and typically downwind of, Clairton Coke Works. In addition, ACHD began monitoring for benzene and other toxic gasses at its West Mifflin monitor site after U.S. Steel began burning off (“flaring”) excess coke oven gas earlier this year at its Irvin Works in Dravosburg. The bad news begins with the fact that ACHD does not provide benzene monitoring data in the same transparent, timely manner as it does for other data on air contaminants such as PM2.5, H2S, and sulfur dioxide (SO2). ACHD’s benzene monitoring method does not provide real-time results; laboratory analysis is required. But even when the analysis is complete, the Department does not publish benzene monitoring results on its website. This means members of the public who wish to review that information must formally request it through the County’s Right to Know process. More troubling is that the time for benzene data delivery from the lab to ACHD often involves months of delay, meaning the most “current” benzene data is months old. Most troubling of all—the worst of the bad news—is that the Liberty Monitor data show concentrations of benzene well below Occupational Safety and Health Administration limits (workplace safety levels), but still above acceptable risk levels for ambient air. As the graph indicates, the average benzene concentration at the Liberty Monitor has been very close to 1 part per billion (ppb) over the past year. The EPA has calculated this level to potentially cause one in 100,000 excess cases of cancer, but the World Health Organization states that as a carcinogen, “no safe level of exposure (to benzene) can be recommended.” U.S. regulators also calculate a level of exposure they expect to cause no appreciable risk of an adverse health outcome. These “non-cancer” effects include a reduced red blood cell count as well as other adverse impacts on the immune and developmental systems. The table shows only the U.S. Agency for Toxic Substances and Disease Registry’s values as an example. While the several agencies agree long-term exposure to concentrations below 1 ppb are unlikely to have non-cancer effects, the table shows ATSDR believes exposure to levels at or above 9 ppb for even one day could be harmful. The graph shows a benzene concentration of 12.74 ppb at the Liberty Monitor this past December. Such results are concerning, and perhaps even more so considering that benzene is not monitored every day at the Liberty Monitor. In fact, ACHD only samples for benzene from midnight to midnight every third day. That means there is no data for the benzene concentrations on the two days between the graphed results. It’s also important to understand that technical or other factors such as a power outage can occasionally render samples invalid. Consider this: There were 118 calendar days and 40 expected sampling days from Dec. 19, 2018 through April 15, 2019 – roughly the period that pollution-control equipment was out of service at Clairton Coke due to the Christmas Eve fire. Over this nearly four-month period, monitoring data only showed 32 valid results. Although none of these results showed a concentration over 9 ppb, we can only say for sure that a little over 27 percent of the days in that time frame were below 9 ppb. Also, as with any monitor, the data only represents a concentration at one point on a map. Thus, it can only detect what the wind or local air currents bring past that site. As noted above, Clairton Coke emits thousands of pounds of benzene annually, but the Liberty and West Mifflin monitors might not show the highest concentration that communities are being exposed to if a strong wind is blowing in a direction away from those monitors. Toxic air pollutants are an issue in every metropolitan area of this country and even in rural and suburban areas, the presence of heavy traffic or an industrial site could be a cause for concern. Allegheny County is no different in this respect, but unfortunately, the data show one area of the County is more affected than most: the Mon Valley ACHD measures benzene and other toxic air pollutants at three sites in the County: Avalon Borough, downtown Pittsburgh, and at Liberty Monitor. Without variation, the Liberty Monitor shows the highest readings. The 2018 Allegheny County Air Quality Annual Report posted to the ACHD website earlier this month indicates the annual average benzene concentration in downtown Pittsburgh at Flag Plaza was 0.37 ppb. The graph shows—and ACHD’s Report confirms—that over the same period, benzene barely registered in Avalon but was 0.96 ppb at the Liberty Monitor. The takeaways? Monitoring data near the largest source of benzene in Allegheny County consistently show that benzene in the ambient air near that facility is the highest in the county. Data also show improvements over the past several years, but there’s continued cause for concern. Several questions remain unanswered. Chief among them: How much longer will Mon Valley residents be subjected to this—and numerous other public health issues—that can reasonably be attributed to emissions emanating from U.S. Steel’s Clairton Coke Works? And if U.S. Steel won’t voluntarily clean up its act, ACHD must exercise its authority to force the company’s hand and require it to adhere to stronger regulations, enforcement efforts and sanctions that truly penalize noncompliance—but will it? Several things are certain: ACHD can—and should—make this benzene data more easily accessible to the public—and in a timelier fashion. Because all of Allegheny County, including the Mon Valley, have a right to know what’s in the air they breathe.