Photo courtesy of the HECA website. UPDATE: Erie Coke Works on March 7 filed an appeal to DEP’s Feb. 14 order. The Department of Environmental Protection’s (DEP) Northwest Regional office on Feb. 4 issued an administrative order to Erie Coke Corp. (ECC) demanding it take action to correct air quality violations believed to be “ongoing and continuous” during the previous 18 months. The order lists 59 regulatory violations Erie Coke committed between June 3, 2017 and Oct. 11, 2018. These violations included exceedances of opacity limits for emissions from the coke ovens, illegally bypassing required hydrogen sulfide absorption equipment, and violating quarterly continuous monitoring standards, among others. It appears that Erie Coke had a chance to avoid the order but was unable to address the issues to DEP’s satisfaction. DEP officials—including Regional Manager Eric Gustafson—met with representatives from Erie Coke Nov. 8 to discuss the violations. Those company representatives included Paul Saffrin and plant supervisor Anthony Nearhoof. DEP meeting minutes from the gathering indicate that the department “hand-delivered a compliance review notification to ECC requesting them to determine what they want to do and how they will proceed.” On Dec. 21, Erie Coke’s attorney(s) responded to this meeting with a letter, although the Feb. 4 order noted this correspondence contained only a “general outline of a compliance plan and no schedule for implementation.” The order can still be appealed by Erie Coke, which has previously run afoul of air quality regulations. In 2010, DEP and the company entered into a Consent Decree to settle a series of violations that went unaddressed from 2008 to 2010. That agreement included a $6 million fine and required Erie Coke to complete a floor-up rebuild of all of the 23 coke ovens in the A-Battery. The company satisfied the terms of the agreement in 2015, but then the EPA filed an enforcement action against it for numerous violations related to leaks of benzene from the facility’s coke by-products area in 2016. GASP became involved with this issue late last year after newly formed group Hold Erie Coke Accountable asked us to assist them in preparing comments on Erie Coke’s Title V operating permit, which is up for renewal. As many GASP supporters know, we have an unfortunate familiarity with the myriad pollution issues caused by coke facilities and were happy to help. Although DEP’s administrative order might put the Title V permit on hold for a while, GASP is committed to assisting and supporting our northern allies in their fight to clean up their air. We sincerely appreciate the funding we’ve received from several local community members that makes it possible for GASP to get involved. #DepartmentofEnvironmentalProtection #consentdecree #ErieCokeCorp #PaulSaffrin #emissions #DEP #EricGustafson #airquality

Comments made to the Allegheny County Board of Health by Sue Seppi, Sep. 13, 2017 Waking up in the morning or the middle of the night to “rotten egg odors” is not an uncommon event in Allegheny County, especially in or downwind of the Monongahela Valley. That smell very likely comes from hydrogen sulfide (H2S), whose odor is perceptible by most at a very low concentration. Of course, there are other disagreeable outdoor odors, but the H2S odor is so unpleasant and common that Pennsylvania has required H2S in the ambient air to be below .005 parts per million (ppm), averaged over 24 hours. This standard has been adopted and is enforceable by the Allegheny County Health Department (ACHD) Air Quality Program. The World Health Organization states, “in order to avoid substantial complaints about odor annoyance among the exposed population, hydrogen sulfide concentrations should not be allowed to exceed 7 µg/m3 (0.005 ppm), with a 30-minute averaging period.” Pennsylvania’s more lenient averaging time of 24 hours allows for considerably higher hourly H2S levels. High hourly concentrations usually occur at night or early morning during our region’s frequent atmospheric inversions, when pollutants get trapped in chilled ground level air. H2S is also heavier than air, so it may stick close to the ground at breathing level. Recently, the public received a new option— to not just hold their noses but to report these window-slamming odors to the ACHD Air Program with the Smell PGH app, developed by the CREATE Lab at Carnegie Mellon University. The Smell PGH app recorded 396 specific “rotten egg” odor complaints between September 29, 2016 and September 5, 2017. Additional “rotten egg” malodor complaints likely were made directly to the ACHD Air Quality Program or to Smell PGH, but with the smell description on the app left blank. Most of the time there are consequences which force improvements when air quality standards are breached, but for the 24 hour H2S standard in the Mon Valley, not so much. This standard, even with the generous 24 hour averaging period, has been significantly violated at the air pollution monitor in Liberty: YearViolations of .005 ppm standard 2017 through 9/535 201641 201587 201449 201328 201265 Is the Allegheny County Air Quality Program paying enough attention to excessive hydrogen sulfide or other odor issues? Some citizens in the Mon Valley area have resorted to litigation, recently suing U.S. Steel in part because of “noxious odors” alleged to be caused by U.S. Steel’s Clairton Coke Plant air emissions. Recently the Pennsylvania Supreme Court affirmed a broad interpretation of Article 1 Section 27 of the Pennsylvania State Constitution. Section 27 affirms a Pennsylvania citizen’s right to clean air and the preservation of the aesthetic values of the environment. GASP urges the Board of Health to require the County Air Quality Program to do better—to develop and implement a plan to eliminate violations of the H2S standard and to be held accountable for improvement. Odor is the most recognizable part of air quality. We’ll never really be worthy of our high rankings on the “Most Livable Cities” or other lists until we must achieve healthy, agreeable air quality. #SmellPGHapp #airpollution #SueSeppi #USSteel #Article1Section27 #CREATELab #noxiousodors #airquality

Last summer, Pittsburgh Public Schools and the bus companies that provide student transportation to them finalized their Pupil Transportation Agreement. Part of the contract included the stipulation (shown at the end of this post) that requires all school buses being used to be equipped with emission reduction technology that greatly reduces the amount of toxic diesel air pollution being emitted by each bus. A recent Right-to-Know request conducted by GASP revealed that approximately 92 percent of the buses being utilized are 2007 model year or newer, or have been retrofit with emission reduction technology. 2007 was the year EPA required 100 percent of the manufactured on-road diesel vehicles to come equipped with diesel particulate filters. This is a significant improvement over the 2015 tally, provided by the school district, which indicated that only 45 percent of the buses were new or retrofit. We are pleased that Pittsburgh Public Schools and the various companies that serve them took seriously our calls to clean up the buses, by agreeing to include this practical and important language in the contracts, and we are happy with the progress that has been made. However, it is necessary for the remaining 20 or so buses to be replaced or retrofit in the immediate future. These remaining older buses are considerably dirtier than newer/retrofit buses and no student should have to ride them. These contracts went into effect at the beginning of the 2016-17 school year, so all buses should be compliant by now. Diesel exhaust poses one of the greatest cancer risks from any type of toxic outdoor pollution in the region. Diesel particles are also linked to asthma attacks, heart attacks, stroke, diabetes, and reduced brain function. Children are especially vulnerable to poor air quality, as they breathe at a faster rate than adults and have a diminished ability to detoxify and excrete many chemical toxins. And since their bodies are still developing, damage from air pollution now could impact their bodies and minds for years to come. Right now 15 percent of the school buses used at Pittsburgh Public Schools are nearing retirement age. Going forward, the school district and bus companies that serve them need to think long term. What can the school district and the bus companies do to minimize their impact on human health and reduce their carbon footprint? What opportunities can they take advantage of to replace diesel buses with less polluting ones, by transitioning to all-electric buses, for example? School districts, bus companies, municipalities, and other diesel fleet owners should start thinking now about projects that could be funded by local, state, and federal funding. One possible source of funding is the Volkswagen settlement money coming to Pennsylvania. According to a Pittsburgh Post-Gazette December 2016 article, “Pennsylvania is slated to receive more than $110 million to reduce air pollution from vehicles, ferries and other diesel-powered machines under the terms of a settlement with Volkswagen over the car company’s emissions-cheating scheme.” Another source could be Allegheny County Clean Air Funds. At GASP we are happy to help interested groups search and apply for funding. Contact rachel@gasp-pgh.org with questions and ideas. –Rachel Filippini, Executive Director Contract language: “CARRIER agrees that the age of all school bus constructed vehicles made available to the DISTRICT during the term of this agreement shall not exceed twelve (12) model years and shall be manufactured in 2007 or later, except for such school bus constructed vehicles as are equipped with diesel particulate filters (DPFs) and closed crankcase ventilation systems (CCVs), which may be manufactured not earlier than 2005 and shall not exceed twelve (12) model years in age.” #dieselexhaust #airpollution #PittsburghPublicSchools #diesel #AlleghenyCountyHealthDepartment #CleanAirFund #ACHD #dieselemissions #airquality

On September 14, at the Allegheny County Board of Health meeting, a dozen local community and environmental non-profit organizations delivered a letter calling on Dr. Karen Hacker, Director of the Allegheny County Health Department (ACHD), to issue an operating permit to the McConway & Torley plant that would prioritize community health by meaningfully reducing emissions of benzene, manganese, and other air pollution from the facility. This follows the efforts of residents who presented 800 petitions in March, calling for a strong permit to be issued in a timely manner. In April of 2015, the Allegheny County Health Department proposed an operating permit for McConway & Torley that would have significantly reduced the amount of harmful air pollution released, but the permit has still not been issued. Thanks to all the groups that signed on and all residents concerned about air quality who have stayed focused on this issue. Full letter: Dear Dr. Hacker, We the undersigned organizations urge you to finalize a strong permit for the McConway & Torley steel foundry that includes local emission reductions and improves the air quality for those who live and work in Pittsburgh, especially in the Lawrenceville neighborhood where the plant is located. Pittsburgh has some of the worst air quality in the country. Our region receives failing grades in the American Lung Association’s State of the Air report which places us as the 8th most polluted region nationwide for year-round particle pollution and 14th for short-term particle pollution. The health effects of air pollution are well-documented. Increased exposure to dirty air can lead to lung disease, asthma, heart attacks, and strokes. According to a University of Pittsburgh, Graduate School of Public Health study, Allegheny County residents have twice the risk of cancer from air toxins compared to those living in nearby rural areas. Air pollution-related diseases also led to an estimated 14,636 premature deaths in western Pennsylvania between 2000 and 2008 according to an investigation by the Pittsburgh Post-Gazette. Among the worst polluters in Allegheny County is the McConway and Torley steel foundry in Lawrenceville. The plant was ranked 8th on Penn Environment’s Toxic Ten Report, which ranked point sources within the county, because it is a proven polluter of toxic emissions that are harmful to our health. These include soot, the neurotoxin manganese, and the carcinogen benzene. Based on 2014 reported emissions, McConway & Torley was the third-largest stationary source of benzene and fifth largest stationary source of manganese in Allegheny County. In addition, noxious odors and heavy truck traffic, from the facility impact the quality of life for nearby community members. Last April, the Health Department proposed a permit for McConway and Torley that would have reduced the release of harmful air toxins, but this permit was pulled for revisions and we are still waiting for a new draft. The more than 147,000 residents living within 3 miles of the facility need a strong permit to be issued in a timely manner. The new permit needs to prioritize the health of nearby residents. The permit must ensure the facility is operating at levels that prioritizes the health of those in the region and require the continuous use of emission reduction technology such as the baghouses. In addition the health department needs to use the most stringent level for assessing manganese, the US EPA Integrated Risk Information System (IRIS). We also need to continue and expand fenceline monitoring, including putting a monitor downwind from the facility and start monitoring for benzene, to get a better assessment of the pollution in the area. It’s time for McConway & Torley to be a good neighbor and take action to reduce the harmful pollutants they are emitting into our air. That’s why I am writing you to urge you to draft a permit in a timely manner that prioritizes our health and leads to marked reductions in toxic chemicals, especially manganese, benzene, and chromium. Sincerely, Steve Hvozdovich State Campaigns Director Clean Water Action Larry Schweiger President Citizens for Pennsylvania’s Future Danielle Crumrine Executive Director Tree Pittsburgh Scott Bricker Executive Director Bike Pittsburgh Rachel Filippini Executive Director Group Against Smog and Pollution Tom Schuster Senior Campaigns Representative Sierra Club Thaddeus Popovich Co-founder Allegheny County Clean Air Now Emily Collins Executive Director Fair Shake Environmental Legal Services Kevin Stewart Director of Environmental Health American Lung Association Thurm Brendlinger Program Director Clean Air Council Patrice Tomcik Field Organizer Moms Clean Air Force Michelle Naccarati-Chapkis Executive Director Women for a Healthy Environment #Lawrenceville #airpollution #McConwayampTorley #AlleghenyCountyHealthDepartment #particlepollution #ACHD #airquality

GASP on Feb. 14 submitted formal comments related to draft installation permits for the Eastman Chemical’s Jefferson Hills facility, along with a petition with nearly 250 signatures. Here’s what you need to know about the issue: Eastman Chemical Resins, Inc. (Eastman) operates a plant in Jefferson Hills which, according to the company’s web page, “produces hydrocarbon resins and dispersions used primarily in hot melt adhesives, rubber and plastic compounding, coatings, sealants, and plastic modification.” Eastman’s plant includes five manufacturing process units: four polymerization process units (the C-5, MP-Poly, Water White Poly, and Thermal Poly Process Units) and a Hydrogenation Process Unit. These units create most of the air pollution emitted by the plant. The plant also includes a Waste Water Treatment Plant, a Pilot Plant used to test new formulas and processes, and approximately 200 chemical storage tanks of varying sizes. Eastman’s plant is a major source of volatile organic compounds (VOCs), which are a criteria air pollutant regulated under the Clean Air Act as a precursor to ozone. Accordingly, the Clean Air Act requires that the plant have a Title V Operating Permit. In Allegheny County, Title V Operating Permits are issued by the Allegheny County Health Department (“ACHD”). These permits are important tools for ensuring major sources comply with air pollution law requirements. A source’s Title V Operating Permit must include all of the federal, state, and local air pollution law requirements that apply to the source, and the source must report annually on its compliance with those requirements. ACHD’s own regulations purportedly required that the plant would have its Title V Operating Permit issued by November 2004. However, ACHD has yet to issue a Title V Operating Permit to the plant. What explains this delay? ACHD was generally slow to issue Title V Operating Permits to major sources of air pollution in the county after its Title V Operating Permit program was approved by the United States Environmental Protection Agency (EPA) in November 2001. Eastman was one of many sites that lingered in ACHD’s backlog of unissued Title V Operating Permits in the 2000s. Since 2011, however, ACHD has not had full control over Eastman’s application for a Title V Operating Permit. In December 2011, the United States and ACHD brought an enforcement action against Eastman under the Clean Air Act. The Complaint in that action alleged numerous violations by Eastman of operating limitations, monitoring requirements, and recordkeeping requirements which it was subject to. More specifically, the Complaint alleged that Eastman failed to monitor and control the temperature of the coolant in the condensers (and related equipment) that controlled emissions from the various processes and tanks in its plant, and that Eastman failed to keep required records that would demonstrate compliance with the operating requirements that applied to those condensers. The claims against Eastman were resolved by a Consent Order which was filed simultaneously with the Complaint. The Consent Order required Eastman to develop emission testing protocols for certain equipment associated with the process units and for many of the storage tanks in its plant, and submit those protocols to EPA for its approval. Following each protocol approval, Eastman was to perform an emission test according to the protocol. Eastman was required to then submit a report regarding each test to EPA for approval. Once EPA approved the reports, Eastman was required to submit permit applications for those units to ACHD for its approval. Notably, the Consent Order imposed time limits on Eastman for its required actions, but did not set any time limits on EPA or ACHD for their approvals or denials of any submissions required of Eastman. The implementation of the Consent Order has not proceeded smoothly or expeditiously. EPA took until October 2012 to approve certain testing protocols that Eastman was required to submit in January 2012. EPA took about 18 months to approve other testing protocols that Eastman was required to submit by early March 2012. As a result, Eastman did not conduct testing of these protocols until the spring of 2013 and the spring of 2014 respectively. After Eastman submitted certain testing reports, EPA required Eastman to supplement them. Some reports had to be supplemented two or even three times, dragging the process out for years. Further, the testing protocols for the plant’s C-5 Process Unit and Waste Water Treatment Plant, which were submitted in 2012 and approved in September 2013, apparently proved to be inadequate. Eastman had to perform additional emissions tests on the C-5 Process Unit in 2016 and 2018, and an additional emissions test on its Waste Water Treatment Plant in 2018. Accordingly, it was not until 2017 that the information necessary for permit applications for at least some of Eastman’s process units was available. Eastman began to submit permit applications for the first of those units in the spring of 2017, and they continued submitting applications through 2018. Very recently (in late 2018 or early 2019), Eastman filed permit applications to modify the requirements for certain equipment in the C-5 Process Unit and increase its authorized production rate and allowable emissions of particulate matter. Although it has been more than seven years since the entry of the Consent Order, Eastman has yet to submit a permit application for the Hydrogenation Process Unit, the Waste Water Treatment Plant, or (it appears) the Pilot Plant. It is well past time for Eastman, EPA, and ACHD to comply with the terms of the Consent Order that was approved in Dec. 2011. The issuance of Eastman’s Title V Operating Permit pursuant to the requirements of the December 2011 Consent Order will be an important step forward for compliance with the air pollution laws in our region. ACHD is accepting written comments through Feb. 14, 2019 regarding Eastman’s applications to modify its existing installation permits so that it may increase its production rate and emission of particulate matter. ACHD’s air pollution regulations allow it to deny an application for an installation permit for a major source like Eastman if the operator does not have all required operating permits for its facilities in Pennsylvania. Join us in urging ACHD to withhold authorization of these permit modifications until Eastman has fulfilled the obligations that were imposed on it by the December 2011 Consent Order, including the obligation to submit permit applications for all of the processes at its plant. — John Baillie, Staff Attorney #volatileorganiccompounds #airpollution #TitleV #JohnBaillie #ConsentOrder #VOCs #CleanAirAct #AlleghenyCountyHealthDepartment #ACHD #EastmanChemical

Methane is the second-most prevalent greenhouse gas in the U.S., and at least a quarter of it comes from our natural gas industry. It’s more than 80 times more potent than carbon dioxide over a 20-year span. Methane emissions from this industry must be addressed if we are to combat climate change. Public health is at risk from climate change. Our health is also endangered by the volatile organic compounds themselves in the gas, and higher levels of ozone, of which volatile organic compounds are precursors. Benzene, ethylbenzene, and n-hexane are examples of air pollution emitted by the natural gas industry. This air pollution causes health effects from dizziness to respiratory impairment to cancer. Beyond the health and climate risks, these leaks are extremely wasteful. In 2014 the industry leaked $1 billion worth of natural gas—enough to heat almost every home in Pennsylvania. By stopping leaks, the industry will have more product to sell. Many fixes pay for themselves quite quickly. In August of 2015, the Environmental Protection Agency (EPA) proposed rules to reduce methane and volatile organic compound pollution from the natural gas and oil sector, starting with new and modified sources. The ultimate goal of the EPA is tair o reduce methane emissions 40-45% from 2012 levels by 2025. The improved standards addressed fixing leaks, “green” completions, and limiting air pollution from different types of equipment like compressor engines and pneumatic controllers. President Obama recently announced similar proposals to address existing sources. Information is being gathered now to identify the largest sources of emissions from existing operations. Here in Pennsylvania, the nation’s #2 natural gas producer, Governor Wolf is taking his own action. His framework to reduce methane and volatile organic compounds was released in January. The plan addresses well sites, compressor stations, pipelines and more, for both new and existing operations. The plan includes components already used by industry leaders or mandated in other states. Governor Tom Wolf ’s 4-point plan will reduce leaks at: 1) New gas well pads by developing a new general permit for exploration/production/processing, requiring “Best Available Technology” for equipment and processes, better record keeping, and quarterly monitoring inspections. 2) New compressor stations and processing facilities by revising its current general permit (GP-5), updating Best Available Technology requirements and requiring more stringent Leak Detection and Repair, among other requirements such as the use of cleaner running Tier 4 diesel engines. 3) At existing sources. The PA Department of Environmental Protection will develop regulations for the Environmental Quality Board to consider. 4) Along pipelines through best management practices, including Leak Detection and Repair. Currently, there is generally no methane monitoring, leak detection, or control of fugitives from transmission or distribution pipelines. Stick with GASP to stay abreast of this issue, especially on our website or on Twitter @GASPPgh, as we expect more movement on this soon—and we’ll need you to weigh in in support of strong regulations that better protect our air quality and public health. #airpollution #methane #compressorstations #emissions #DEP #airquality

Editor's Note: The petition period is now closed. Thank you to all who signed. Allegheny County’s air quality is among the worst in the nation, ranking in the top 2 percent of U.S. counties for cancer risk from inhaled air pollution. Our region consistently struggles to meet the federal health-based standards for harmful ozone and fine particulates. Actions must be taken to improve our air quality and protect our health. The Clean Air and Title V Funds are designated for air quality improvement projects and regulating major sources of air pollution. The Health Department wants to use millions of dollars from these funds to renovate an office building instead. Allegheny County residents, please sign our petition to let the Allegheny County Board of Health know that you disagree with their choice to use this money on an office renovation, and that you support the money being used to on projects and programs that will clean our air. Learn more about our lawsuit to stop this illegal use of funds. #fineparticulates #airpollution #TitleV #petition #renovation #AlleghenyCountyHealthDepartment #CleanAirFund #airquality

The Allegheny County Health Department (ACHD) ended 2020 without having taken action on required air quality operating permits for six of 31 major sources of air pollution, according to the results of an annual audit. The 17-page report issued Sept. 27 by Allegheny County Controller Chelsea Wagner notes that ACHD failed to either issue or deny Title V operating permits to the following companies within the time frames required by the Clean Air Act: Bellefield Boiler Plant U.S. Steel’s Clairton Coke Works facility Sunoco Partners Marketing and Terminals (formerly Sun Oil Pittsburgh Terminals) Harsco Metals Allegheny County Sanitary Authority (ALCOSAN) ATI Flatrolled Products (formerly Allegheny Ludlum) In addition, Eastman Chemical Resins, Inc., a major source, has never been issued a Title V permit. Eastman has been working through the requirements of a 2011 consent order and should submit its application for a Title V permit pursuant to that consent order this coming fall or winter. The audit indicates that while progress has been made to eliminate the Title V permit backlog, the department still has a long way to go, an issue GASP has investigated annually and most recently reported on back in May. You can read more on our Watchdog Report. You can read the entire audit here. #SunocoPartnersMarketingandTerminals #AlleghenyCountyControllerChelseaWagner #ATIFlatrolledProducts #BellefieldBoiler #USSteel #AlleghenyCountySanitaryAuthority #TitleVpermitbacklog #audit #CleanAirFund #ClairtonCokeWorks #EastmanChemical #ALCOSAN

The U.S. Environmental Protection Agency (EPA) earlier this month announced a proposal that - if approved - would mean four municipalities in our area would no longer meet a national air quality standard for sulfur dioxide (SO2), a harmful air pollutant emitted from fossil fuel combustion and other industrial processes. Specifically, the EPA is proposing to redesignate Lower Yoder Township in Cambria County and St. Clair Township, Seward Borough, and New Florence Borough in Westmoreland County as being in nonattainment for the one-hour 2012 National Ambient Air Quality standard (NAAQS) for SO2. Sound a little like word soup? We get it. Here’s why this is kind of a big deal: EPA’s proposed redesignation will create a nonattainment area that is separate from, but adjacent to, an existing SO2 nonattainment area that consists of all of Indiana County, as well as Plum Creek Township, South Bend Township, and Elderton Borough in Armstrong County. In an interesting about face, EPA’s proposed redesignation is based in part on air quality modeling that environmental groups submitted to EPA in 2018 based on emissions data from 2013 through 2018. EPA now admits that it did not fully consider this data in 2020 when it determined that the proposed new nonattainment area was either “unclassifiable” or “attainment/unclassifiable.”  That data showed that the proposed new non-attainment area suffered from levels of SO2 pollution that exceeded the NAAQS. A little bit of background on process and some of those technical terms: The Clean Air Act requires EPA to designate areas that do not meet a NAAQS as nonattainment for that NAAQS. Once an area has been designated as nonattainment, the state in which it lies must develop what’s known as a State Implementation Plan (SIP) that demonstrates the area will attain the NAAQS within five years of EPA’s designation. “A SIP for a nonattainment area is typically based on new emission limits for sources of pollution but may also be based on the reduction of pollution due to equipment upgrades, plant retirements, or the like,” GASP senior attorney John Baillie said. In Western Pennsylvania, the most significant sources of sulfur dioxide pollution are large facilities that burn coal. Until relatively recently, the already-existing and proposed SO2 nonattainment area in Indiana and Armstrong Counties was home to four power plants that burned coal and contributed to locally high levels of SO2 pollution: Keystone Generating Station in Plum Creek Township, Armstrong County Conemaugh Generating Station in West Wheatfield Township, Indiana County Homer City Generating Station in Center Township, Indiana County and Seward Generating Station in East Wheatfield Township, Indiana County The SO2 emitted by those facilities was the principal cause of both the existing and proposed new nonattainment designations. But note: Homer City ceased operations in mid-2023, and Keystone and Conemaugh are scheduled to cease operations by no later than 2028. It is logical to expect that attainment will follow once such large sources of SO2 cease emitting. “It is entirely possible that three of the four large sources of SO2 emissions that impact that proposed new nonattainment area will be shut down before the date by which the area must finally attain the SO2 NAAQS,” Baillie explained.  “In that case, no additional controls or measures may need to be added to Pennsylvania’s SIP. The only real result of EPA’s eleventh-hour about-face on modeling and redesignation of the new nonattainment area will have been to increase paperwork for itself and DEP.” Editor’s Note: GASP continues to follow this issue closely. We will keep you posted.

The Allegheny County Health Department (ACHD) periodically updates its website with recent Air Quality Program enforcement actions. That docket can be viewed here. These are the latest entries, with violations related to asbestos abatement, failure to report an equipment breakdown, and air quality permit infractions. Asbestos Abatement Violations Before we tell you about the latest violations, we wanted to make sure you understood what the rules related to asbestos actually are. Allegheny County Health Department’s rules require an asbestos survey (a thorough inspection to determine the presence of asbestos) for all renovation and demolition projects and depending on the quantity of asbestos identified, proper notification, specific work practices, and proper disposal of asbestos-containing material are required. The notification requirements for facility demolition and renovation activities are dependent upon the amount of asbestos-containing (ACM) material at the site. If less than 160 square feet of ACM is identified in the facility, a properly completed notification must be submitted 10 days before demolition or renovation activity begins. If the amount of ACM is 160 square feet or more, a properly completed permit application must be submitted with appropriate payment at least 10 working days before the asbestos abatement begins. A licensed asbestos contractor must remove all ACM identified as described in the permit. Demolition or renovation activities may proceed once ACHD has performed a final clearance inspection. But back to those enforcement actions – ACHD issued notices of violation recently against: The City of Pittsburgh, Deller Professional Services, General Contracting Corp. Schaaf Excavating, and Unis Demolition Co. on Nov. 10 for various asbestos-related violations. The enforcement order assessed a $38,500 civil penalty. The violations stem from the demolition of various blighted properties without the proper asbestos clearances. You can read the entire enforcement action here. Community College of Allegheny County (Boyce Campus) on Nov. 21 for the unauthorized removal of containment barriers and reopening to the public an area being abated for asbestos-containing material. The contractor responsible for the abatement work was CSI construction. You can read the entire enforcement action here. Deller Professional Services on Dec. 14 for removing containment barriers while demolishing a property located at 6338 Shetland Street in Pittsburgh prior to ACHD completing a final inspection. You can read the entire enforcement action here. Kevin Fisher on Dec. 14 for renovating a property located at 5401 Penn Avenue in Pittsburgh and removing potential asbestos-containing material before obtaining an asbestos survey. You can read the entire enforcement action here. West Deer Township and CSI Construction on Nov. 9 for failing to complete proper air sampling, conducting abatement activity without proper public signage, and for the unauthorized removal of containment barriers. All of these violations were related to renovations at three residential properties in the municipality. You can read the entire enforcement action here. ACHD on Dec. 22 issued a scheduling order in the high-profile case against Churchill Community Development and Paradigm Consultants and its chief executive Vikas Jain. Jain in October 2019 pleaded guilty to illegally dumping asbestos-containing material generated during the renovation of the former George Westinghouse Research and Technology Park in Churchill Borough. Jain had been charged with one count of knowingly violating work practice standards of the Clean Air Act following an investigation by the FBI and Environmental Protection Agency (EPA).  The order scheduled an administrative hearing for 9:30 a.m. Feb. 23 and Feb. 24. You can read more about the case here and here. Breakdown Report Violation ACHD on Dec. 10 issued a notice of violation to Neville Island-based INEOS Composites US LLC located at 2650 Neville Road for failure to timely report a breakdown of air pollution-control equipment. By way of background: The company manufactures and sells a broad range of unsaturated polyester and vinyl ester resins. INEOS on Aug. 26 provided written notice of a breakdown of its Polyester Resin Plant Thermal Oxidizer because of a power outage. The time of the breakdown, though, was from 9:30 a.m. and 9:45 a.m. Aug. 21. For those who might not be aware: Allegheny County Air Pollution rules require operators responsible for emissions-control equipment to report breakdowns within an hour of them commencing. Written notification of breakdowns is required no later than seven days following the incident. The Nov. 9 notice of violation noted: “The breakdown was not called into the ACHD. In a subsequent communication, an INEOS representative stated that the breakdown was inadvertently called to an incorrect ACHD telephone number; however, no record of such call is available. The ACHD was not notified of the breakdown until the written notification was received.” You can read the entire enforcement action here. Title V Air Quality Permit Bookkeeping Violation Noted ACHD issued a notice of violation against Indianola-based Buckeye Terminal LLC for failing to timely submit its annual Certificate of Compliance as required by its Title V air quality operating permit. You can read the entire enforcement action here. #CSIConstruction #airuality #SchaafExcavating #Asbestos #asbestosabatement #UnisDemolition #INEOSCompositesUS #AlleghenyCountyHealthDepartment #ACM #ACHD #DellerProfessionalServices