Editor’s Note: Big thank you to WTAE Investigative Reporter Paul Van Osdel for his story about this air quality backlog issue. You can check out the story and video featuring GASP’s investigation and analysis from our senior attorney John Baillie here. Remember when we blogged about the status of the Title V Operating Permit programs at the Allegheny County Health Department and the Pennsylvania Department of Environmental Protection’s (DEP) six regional offices in May of this year? Because we have an update: Since then, we’ve learned new information about several Title V facilities under the jurisdiction of DEP’s Southwest Regional Office and want to pass it along to provide you with the most accurate, up-to-date info out there. By way of background, when it comes to air quality permitting, the DEP’s Southwest Regional Office includes pollution sources in Beaver, Cambria, Fayette, Greene, Somerset, Washington, and Westmoreland Counties. Since we blogged about the status of Title V Operating Permits under the jurisdiction of that office in May, we’ve learned one facility we included in the list of those backlogged permits – the Equitrans Pratt Compressor Station in Greene County – has shut down. Another facility included on the list – the Equitrans Hartson Compressor Station in Washington County – became a minor source and has an up-to-date minor source operating permit that was issued earlier in 2023. Two further facilities – the Shade Landfill in Somerset County and Langeloth Steel in Washington County – were issued Title V Operating Permits in 2022. So, based on this new information, we count: 50 major sources with backlogged permits are under review by DEP’s Southwest Regional Office One major source in the Southwest Region - the Brunner Landfill in Beaver County - applied for but has never been issued a Title V Operating Permit. Brunner Landfill has yet to pass a stack test necessary to obtain the plan approval that it needs before applying for a Title V Operating Permit. Two major sources in the Southwest Region –Hill Top Energy Center in Greene County and Tenaska Westmoreland Generating Station in Westmoreland County – have been constructed and are temporarily operating under the authority of their plan approvals - or preconstruction permits - but have not yet applied for their Title V Operating Permits (the air pollution regulations permit this during the start-up process for a facility). Another new source – CPV Fairview Energy Center in Cambria County – has applied for its first Title V Operating Permit and DEP recently made a draft of that Permit available for public comment. Four sources in the Southwest Region still have renewal applications for operating permits that have been pending for more than 18 months: Here’s a revised summary of what the permit backlogs at ACHD and DEP’s regional offices have looked like since 2018: ------------------ Check out our Title V Air Quality Permit Clearinghouse to get the skinny on pollution sources near you.

As wildfire smoke enveloped our region at the end of June and air quality plummeted, we heard (and thought) one question again and again: Is it safe to go outside? When conditions were at their worst, the simple answer was, “No, not really,” and for a time the EPA’s AirNow platform and Allegheny County Health Department (ACHD) outreach agreed that levels of fine particulate matter (PM2.5) were “very unhealthy,” meaning that the “risk of health effects [was] increased for everyone.” To our dismay, the EPA and ACHD appeared not to agree on the messaging or the Air Quality Index (AQI) a great deal of the time over those three hazy days. Quite often, AirNow values and those ACHD were sharing didn’t line up. The two agencies’ dueling approaches stem from differences in how hourly data is averaged, as well as the very goal of reporting the AQI to the public. From our perspective, the EPA and ACHD taking two different approaches to public outreach when air quality was “very unhealthy” was very unacceptable and potentially dangerous. Actual people with health conditions or vulnerable loved ones were scared, and the two agencies with expertise in both air quality and public health couldn’t get on the same page. What should have been a clear, unified message to the public about the risks of exposure to harmful levels of PM2.5 occasionally descended into color-coded confusion. Public reprimands aside, we want to provide a deeper explanation of why both agencies technically were reporting valid numbers, and also why the EPA was reporting FAR more useful information under the circumstances. Some Necessary Background Info The health-based National Ambient Air Quality Standard for PM2.5 has two components: a daily (24-hour) standard and an annual standard. Even if air quality exceeds those numeric limits – 35 micrograms per cubic meter (ug/m3) and 12.0 ug/m3, respectively – that does not mean air quality violates the standard. The actual regulations state that an area fails to meet the annual standard if the annual concentration averaged over three years exceeds 12.0 ug/m3. Similarly, violating the daily standard requires roughly eight days per year, averaged over three years, to be over 35 ug/m3. If you’re thinking, “That’s a lot of numbers; just tell me what’s healthy and what isn’t,” you aren’t alone. In 1999, the EPA created the Air Quality Index (AQI) to address the complexity of the standard and replace a collection of varying regional approaches. The AQI provided a simple, color-coded way to report past conditions – “there were ‘X’ number of ‘red’ air quality days last month” –and forecast future conditions – “we expect ‘orange’ air quality tomorrow; open burning will be prohibited.” This was a very important step toward improving public health communications because it created a single, national, uniform means of providing accurate, timely, and easily understandable information about daily levels of pollution. However, one problem inherent in the AQI as originally conceived was that it was not set up to address real-time conditions. The Research Improved and the Internet Got Faster This might sound trite, but a lot has changed since 1999. Feel free to reminisce a bit (or ask the internet what it was like way back then), but particularly relevant to this story is that both the internet and public health research have *really* come a long way since the waning days of the previous millennium. For perspective: The first ever EPA standard for PM2.5 was only finalized in 1997 and at least two GASP contributors to this story could still get email via a dial-up modem in 1999. Now that public health officials have decades of research on PM2.5 and the infrastructure exists to monitor and share PM2.5 levels reliably on an hourly basis, updating the 1999 approach to how EPA shares that information became necessary. But there’s one small catch: The extensive, federal, complicated, PM2.5 standard is based on a yearly average and a 24-hour average. You don’t need to be a mathematician to realize a current or real-time PM2.5 level outside is not the average of the previous 24 hours. We graphed the data so you can see for yourself: The solution was EPA’s NowCast AQI (which are the values reported on the AirNow website and app). EPA’s approach is based on a fundamental principle of public health: reducing exposure to potentially harmful substances reduces the risk of an adverse impact on human health. According to an EPA AirNow Knowledgebase article, EPA’s goal was “to report shorter-term data to caution people in time for them to reduce their 24-hour exposure. The NowCast is EPA's method for relating hourly data to the AQI.” In a passage particularly relevant to our hazy June days, the EPA stated that the “NowCast is designed to be responsive to rapidly changing air quality conditions, such as during a wildfire.” The agency continued: “The NowCast allows AirNow's current conditions to align more closely with what people are actually seeing or experiencing.” In no uncertain terms, current information is crucial for a concerned public. Can my kids go out and play? Should I check on my grandma? The bus is running late; is it safe to wait outside? The questions people have when conditions deteriorate and/or change rapidly cannot be answered with a view to the previous 24 hours. And this isn’t just some theoretical exercise for a healthier approach to living. Even though the official PM2.5 standard doesn’t include hourly or other shorter-than-a-day limits, the EPA has acknowledged some studies have shown adverse effects of exposure to levels of PM2.5 over 120 ug/m3 for two hours. When air quality is exceptionally poor, knowing how bad conditions are is very important, and as the EPA put it, the NowCast, “gives people information they can use to protect their health when air quality is poor – and help them get outdoors and get exercise when air quality is good.” Does this mean ACHD was wrong? Only in its approach to public communications. In the same Knowledgebase article we’ve been quoting, the EPA acknowledged “it is not valid to use shorter-term (e.g. hourly) data to calculate an AQI value.” The NowCast AQI published on AirNow.gov does not supersede or invalidate the older approach, it is simply a tool to help the public understand the current conditions. If ACHD publishes an AQI value based on 24 hours of data, that is a valid calculation of the AQI. It just also happens to be of little use for an active, connected, and concerned public. To ACHD’s credit, it added a notice to its website expressly stating that it reports a 24-hour average value, but it then recommended readers access raw data not presented in the AQI format for shorter-term considerations. Call us crazy, but we think promoting airnow.gov is a superior option to ACHD assigning the public math homework before they go outside. As we see it, prevention is the best medicine, and ACHD’s approach isn’t helping. Failing to promote modern and understandable tools meant to protect public health is absurd, and neither the EPA nor ACHD can state sanely that publishing different versions of the AQI serves the public’s best interest. Did you find this blog helpful? We hope so. Truth be told: We think about you all the time. Seriously. Our staffers get up early when we know air quality is expected to be abysmal so we can review the data, crunch the numbers, and let you know what to expect when you start your day. We attend subcommittee meetings, hearings, and webinars because we pride ourselves on being your eyes and ears on all things air quality. Help us continue to show up for all our fellow breathers by making a $5 donation today.

We will ask for your forgiveness now because we will be bragging in this blog. Honestly, our latest Fresh Voices for Clean Air cohort was just too good not to…But we’re getting ahead of ourselves, here. We hope at this point, you’re thinking, “Tell me more about these Fresh Voices, GASP!” Because we’re happy to oblige: Fresh Voices for Clean Air is a project of GASP (Group Against Smog and Pollution here in Pittsburgh) and the Greater-Birmingham Alliance to Stop Pollution (GASP) funded by our friends at the Grable Foundation. Our air quality-focused non-profits hail from cities with similar industrial and environmental histories: While our smoky past had people calling the Golden Triangle “hell with the lid off” a century ago, Birmingham was nicknamed the “Pittsburgh of the South.” “Both cities regularly experience some of the worst air quality in the nation - discovering and discussing the similarities and differences between experiences in these two regions was a key component of the collaboration,” our educator Laura Kuster explained. The program - now in its second year - paired high school students here in Allegheny County with a group of their peers in Birmingham. The groups met virtually over the past 10 months to learn more about air quality and build skills to help them become even more effective environmental advocates. They engaged in internal discussions, chatted with expert guest speakers like Sally Wenzel, Occupational and Environmental Health Chair at the University of Pittsburgh Graduate School of Public Health, and completed a team project that focused on two major incidents near their hometowns with MAJOR air quality implications: The East Palestine rail disaster in Ohio and the Moody Landfill fire in Alabama. “By diving into different aspects of the incidents and sharing our findings, we hoped to clarify why it happened, how residents and government agencies responded, and what implications that are for the future,” Kuster said. Both the research and the outreach materials our Fresh Voices participants crafted were outstanding. Seriously. Take a look for yourself: While our Fresh Voices groups approached their work armed with data and facts, they never lost sight of how the incidents impacted real people. They explored the physical and emotional impacts those air quality emergencies had on the folks who lived near them. You can check out that work, too. That - and more - is on our Fresh Voices for Clean Air page here. We’d be remiss if we didn’t also highlight a poem by one of our local participants, Rho, titled, “To the Politicians Who Keep Voting Against Our Planet." You can watch them recite it here:

Editor's Note: Thank you so much to everyone who expressed interest! All spots have been filled. HOWEVER: Folks interested in learning more about smoke reading are invited to join us out in the field! Email sue@gasp-pgh.org to get more info on upcoming opportunities in a neighborhood near you. Have you ever been driving, saw a huge plume of industrial pollution snaking its way into the sky, and wondered to yourself, “Well, that looks nasty. I wonder if that’s even permitted,” then we have an opportunity for you. Learn the answer to that question and more at an upcoming smoke reading course. Never heard of smoke reading? Smoke readers is a general term applied to people who are trained and certified to recognize and understand visible emissions from sources such as smokestacks, as well as what violations look like, and how to make reports. “Folks are surprised to learn this is the same training received by Allegheny County Visible Emissions Inspectors,” GASP Executive Director Patrick Campbell said. GASP’s project manager Sue Seppi, a longtime smoke reader, said attending the training is an excellent way for citizens to take action in their own communities by observing visible emissions at the facilities that are of concern to them. “Inspectors can’t be at every facility all the time,” she said. “Observations from volunteers who are trained and certified as smoke readers help increase regulatory scrutiny on those neighborhood industrial plumes,” she said. Sound like something you or someone you know would be interested in? Then we have some awesome news: Allegheny County Health Department (ACHD) is covering the cost of the training by Eastern Technical Associates. The caveat? Spots for this opportunity are EXTREMELY limited. The next training is scheduled for late September. Training includes an education day and a field day. The education day is a live webinar held at 9 a.m. every Monday - participants choose which one works best for them. Participants attend the second session in the field on either Sept. 27 or Sept. 28. The field instruction registration begins at 8 a.m. and consists of multiple hourly field observation periods called runs. When you complete one hourly observation successfully you are done and will receive certification. “Once your training is complete, the GASP team can pick up from there to get you started with actual observations in your community,” Campbell said. To attend ETA Visible Emissions training for free through the Allegheny County Health Department, contact sue@gasp-pgh.org to register. You can get more information about smoke school on the Eastern Technical Associates website.

GASP joined residents and fellow advocates Wednesday to tell the Allegheny County Board of Health that October’s abysmal air quality is unacceptable and that action needs to be taken to adjust the Mon Valley Air Pollution Episode Rule and take enforcement action to stem the outrageous exceedances of Pennsylvania’s hydrogen sulfide standard. For those who need a refresher, the air quality in the Mon Valley was REALLY bad last month. You can get the skinny on all that here. Here is what our executive director told the board: Good afternoon, I’m Patrick Campbell, the executive director of the Group Against Smog & Pollution. October was a painful month when it came to air quality, especially for those in the Mon Valley or downwind of it. To its credit, Allegheny County Health Department did issue public alerts notifying residents about obscenely high concentrations of hydrogen sulfide at the Liberty monitor and issued both a Mon Valley Watch and Warning, which spanned four days. Communication on these crucial public health matters equips residents with the knowledge they need to understand air pollution issues and how they can mitigate exposure to protect themselves and their families. These notices and follow-up air quality reminders, while not perfect, were appreciated. GASP hopes ACHD will build on this, providing more responsive, frequent, and detailed alerts when poor air quality is forecast. GASP hopes ACHD will do more to address the pervasive H2S problem. Half of the days in October were marred by H2S exceedances. Because we know that inversions do NOT cause H2S emissions, we are calling on ACHD to take robust enforcement action against what does: U.S. Steel’s coking operations. GASP also urges ACHD to take action now to review and amend the Mon Valley Air Pollution Episode Rule and its implementation to ensure it is working as intended. Of particular interest is how - and when - the department decides to issue a watch or warning and whether adjustments to that process are needed. For example: The threshold to trigger a Mon Valley Air Pollution Warning was reached as of 8 a.m. Oct. 11 and steadily increased throughout the day but a Warning was never issued. We understand that the rule only requires a Warning to be issued if ACHD “has determined atmospheric conditions will continue” to contribute to a likely exceedance of the PM2.5 NAAQS. But considering the NAAQS for PM2.5 was exceeded Oct. 12, ACHD must answer these questions: Why wasn’t a warning issued? Had a warning been issued and industry polluters like U.S. Steel required to enact their mitigation plans and reduce emissions, could the exceedance have been avoided? Thank you. Editor's Note: Here is media coverage of the Board of Health meeting: From the Pittsburgh Post-Gazette: Allegheny County Residents Raise Concerns Over Mon Valley Air Pollution Episode From the Pittsburgh Business Times: Advocates Say Allegheny County Air Pollution Rules Should Be Revisited

Editor’s Note: The Allegheny County Health Department periodically updates its website to include documents related to air quality enforcement actions. As part of our watchdog work, GASP monitors this webpage and reports on the air quality violations posted there. Earlier this week, we told you about the latest enforcement action against U.S. Steel for air quality violations at its Clairton Coke Works facility. Here are the other new cases uploaded to the docket: The Allegheny County Health Department (ACHD) issued a $3,410 civil penalty against Neville Island-based INEOS Composites for failing to report an equipment breakdown and record-keeping issues that stem from an April 2022 facility inspection. According to the enforcement action, an ACHD inspector noted INEOS did not report a temperature exceedance for Maleic Anhydride Storage Tank F-4602 within 60 minutes as required. The company also failed to submit a written report within seven days, as its permit requires. “Plant personnel stated that the incident was due to a steam bypass valve being open that was supposed to be closed,” the document states. “They stated that the previous day, April 13, 2022, they had observed the temperature at 72° C, or 162° F. Plant personnel stated their belief that they were not required to report the incident as a breakdown because it was due to human error.” The June 21 enforcement action notes that “to date, ACHD has not received a written report” addressing the exceedance.” ACHD further indicated that INEOS was unable to provide the inspector with data of daily plant production and the amount of each monomer used for September 2020 and September 2021 - record-keeping that’s also required by its permit. “Plant personnel indicated that they were not keeping and did not believe they were required to keep daily production or monomer usage records,” the document notes. In addition to the civil penalty, ACHD ordered the company to report all breakdowns caused by human error as well as keep daily production or monomer usage records within 30 days and report that usage in the next two semi-annual reports due July 31 and Feb. 1, 2024. You can read the entire enforcement order here. ACHD, ALCOSAN Enter Consent Agreement Over Agency Exceeding Emissions Limits ACHD and ALCOSAN have entered into a consent decree because the authority exceeded emissions limits of harmful air pollutants such as lead and hydrogen chloride - exceedances for which a nearly $6,000 civil penalty was assessed. At this point, we need to stop to understand a little bit of background: ALCOSAN operates a publicly owned treatment works facility located at 3300 Preble Ave. in Pittsburgh that serves 83 local municipalities and processes more than 200 million gallons of wastewater per day on average. ALCOSAN is a minor source of all criteria pollutants and hazardous air pollutants (HAPs), operating two sewage sludge incineration units that must meet specified emission limitations for cadmium, carbon monoxide, dioxins/furans, hydrogen chloride, lead, mercury, nitrogen oxides, particulate matter, and visible emissions. That operating permit requires periodic stack tests to demonstrate compliance with these emission limits on an annual basis. It also allows stack tests for a given pollutant to be performed less often when two prior consecutive stack test results for a given pollutant are at or below 75% of the respective emission limit and there are no changes in operation that could increase emissions. Now back to that enforcement action: It states that from Aug. 25- 27, 2020, ALCOSAN conducted a stack test on one of its SSI units, known as FBI-2, for all the emissions limits we mentioned earlier. On August 28, 2020 - and prior to receiving the August 2020 stack test results - ALCOSAN took FBI-2 out of service. The results of this stack test, which ALCOSAN received and submitted to the ACHD in October 2020, showed that the measured emissions of hydrogen chloride and lead exceeded the emission limits. Subsequent stack tests also showed that the measured emissions of cadmium and lead exceeded the emission limits set forth in its permit. Regarding hydrogen chloride, ACHD examined the June 2021 stack test results and later determined that the stack test results for hydrogen chloride were incomplete and/or invalid - FBI-2 was active in 2021 only long enough to conduct stack testing. ACHD ultimately issued a Notice of Violation against ALCOSAN in December 2021. In the months that followed, ALCOSAN worked with ACHD to conduct testing and sampling. In March 2022, ALCOSAN stack tests demonstrated compliance with emissions limits. As a result, ACHD issued ALCOSAN its operating permit on Sept. 21, 2022. You can read the entire consent decree here.

While there were no action items on the agenda for Wednesday’s Allegheny County Board of Health meeting, members were treated to a lengthy update from health department Interim Director Patrick Dowd, who shared information on monitors on the move, data details related to the most recent rash of wildfire smoke, and goals for reducing both fine particle pollution and sulfur dioxide by 2027. In his environmental health report, Dowd said: The Air Quality Program’s permitting section continues to finalize the development of an online permitting portal, noting that residents should have access by the end of the year. ACHD staff moved the Avalon air quality monitor a few hundred yards from the old location and is preparing to relocate the Lawrenceville monitor to Fulton Street. The Air Quality Program has worked to reduce the amount of unpaid or overdue invoices from $113,624 to $9,267. During an update on administrative matters, Dowd noted that the department is wrapping up the 2024 budgeting process. He said ACHD submitted nine new grant applications over the last three months, totaling $29 million with spending periods ranging from three to five years. It was unclear which programs would benefit from the grants if awarded. He also said ACHD is moving multiple programs from the Clack campus in Lawrenceville to Fulton Street. It is also relocating current programs into revamped spaces in their current leased facilities. No further details we shared. Dowd also provided an update regarding how the recent waves of Canadian wildfire smoke impacted our local air quality. Notably, he said AQI for PM2.5 peaked at 212 (which falls into the EPA’s purple, unhealthy range) at the Parkway East on June 29 - the highest ever recorded in Allegheny County. The former record? It occurred in 2003 when the AQI for PM2.5 hit 175. Dowd also detailed how “ACHD kept residents apprised on changing air quality conditions and provided information on how they could remain healthy.” More on that from GASP tomorrow. Stay tuned. After talking about how air quality has improved over the decades, he reiterated that despite that progress, there was still work to be done. And to that end, he outlined ACHD’s goals on the air quality front. Specifically, he said ACHD’s goal was to: Reduce the annual average PM2.5 concentration by at least 12% (from 9.7 µg/ m³ in 2021 to 8.5 µg/m³ in 2027, on a countywide average basis) Reduce the number of days per year when sulfur dioxide (SO2) exceeds an AQI of 50 (from 36 in 2021 to 26 in 2027) He indicated that ACHD would also prioritize helping local communities “prepare to adapt to changes generated from climate change.” Editor’s Note: You can view the slides presented at the meeting for yourself here.

The Allegheny County Health Department (ACHD) on Tuesday announced it issued $301,725 in stipulated penalties against U.S. Steel for air pollution violations that occurred at the Clairton Coke Works during the third quarter of 2022. The fine was calculated pursuant to ACHD's 2019 settlement agreement with the Mon Valley steelmaker. Per that agreement, 90% of penalties ($271,552.50) will be paid to the Community Benefit Trust for impacted communities while the remaining 10% ($30,172.50) will be paid to the Clean Air Fund. In March 2023, ACHD issued $307,800 in stipulated penalties against U.S. Steel for violations that occurred at the Clairton Coke Works during the second quarter of 2022. To view this enforcement action and other air quality enforcement actions issued by ACHD, click here. Editor's Note: GASP staff is currently reviewing the enforcement action and will keep you posted. In the meantime, you can read the 30-page document for yourself here.

The state Department of Environmental Protection (DEP) recently published notice of what may be the first Reasonably Available Control Technology - or RACT III - determination for a site in southwestern Pennsylvania under DEP’s jurisdiction - one that will lead to emissions reductions in Beaver County. Specifically, DEP determined that the Pike Compressor Station in Beaver County is required to control emissions of volatile organic compounds (VOCs) from rod packing operations with a combustor and emissions of VOCs from compressor blowdowns and startups with an enclosed flare. Based on the Pike Compressor Station’s existing Title V Operating Permit, it appears that such emissions were previously not controlled. We have blogged about the RACT requirement before, but to review: The RACT requirement instructs the states to determine whether major sources of VOCs and oxides of nitrogen (NOx) are using all reasonably available control technology to limit their emissions of NOx and VOCs. NOx and VOCs are the two principal precursors to the formation of ground-level ozone pollution. And the concern about ground-level ozone is that it can trigger a variety of health problems including chest pain, coughing, throat irritation, and congestion. It can worsen bronchitis, emphysema, and asthma. Ozone also can reduce lung function and inflame the lining of the lungs. Repeated exposure may permanently scar lung tissue. If such sources of ozone are not implementing RACT, the states must require them to do so, even if they were properly permitted when they began operating and have continued to operate within all applicable limits. New RACT determinations are required under the Clean Air Act every time a National Ambient Air Quality Standard (NAAQS) for ozone or NOx is revised. Because this is the third time new RACT rules have been required, the new rules are referred to as RACT III. The first round of RACT determinations followed the imposition of the RACT requirement by the 1990 Amendments to the Clean Air Act and was implemented in the late 1990s and early 2000s. RACT II determinations, which were completed just last year, followed the revision of the NAAQS for ozone in 2008 (yes, there really was a 14-year lag!). RACT III follows the latest revision of the ozone standard, which occurred in 2015. Generally, the Clean Air Act requires RACT determinations only for major sources in areas that do not attain the NAAQS for ozone. However, all areas of Pennsylvania are deemed to be nonattainment for the purpose of implementing RACT, because Pennsylvania is included in the “Ozone Transport Region” established by the Clean Air Act. As a result, all major sources of NOx and VOCs in Pennsylvania will be required to comply with RACT III emission limits. DEP’s RACT III determination for the Pike Compressor Station is one of many that will be made in the upcoming months (and years); however, not all of them will result in new controls as this one did. We will keep you updated as DEP’s RACT III determinations continue.

In May, we blogged about Pennsylvania Senate Bills 561 and 562, which would, respectively, exempt vehicles less than five years old from Pennsylvania’s vehicle emissions inspection requirement and exempt vehicles registered in Blair, Cambria, Lackawanna, Luzerne, Lycoming, Mercer, and Westmoreland Counties from such requirements altogether. Although it appeared to us that Senate Bill 561 could be consistent with the Clean Air Act, Senate Bill 562 would seem to violate the Act. We have an update: The full Senate late last month approved both bills, which have been transferred to the House of Representatives for its consideration. We’ll continue to provide updates on these Bills as new developments occur.