Did you hear? The Pennsylvania Department of Environmental Protection (DEP) authorized an air quality plan approval to allow an onsite leachate treatment and evaporation system to be installed at Westmoreland Sanitary Landfill, located in Rostraver Township, Westmoreland County. Leachate is moisture produced by waste itself and stormwater that infiltrates the landfill’s waste. Leachate from landfills must be treated onsite or transported to a separate treatment facility. Evaporating liquid leachate at Westmoreland Sanitary Landfill would eliminate risks of spills, impacts, and traffic associated with trucking leachate offsite for disposal. The air quality plan approval establishes emissions limitations and monitoring requirements. DEP is currently reviewing a waste permit modification application, which, if approved, would authorize the use of the evaporator system for the treatment of the landfill’s leachate. Both the plan approval and waste permit modification must be obtained before operation. The approved leachate treatment and evaporation system includes extensive pre-treatment of the leachate. The evaporator will include a three-stage demisting filtration system with a 99% removal efficiency of filterable particulate matter. The air quality plan approval also includes numerous measures to monitor pollutants that may be emitted through the evaporation process and/or present in the leachate and assure compliance with emission limitations. Modeling and calculations using accepted scientific methods show any radionuclides emitted into the air will not pose a health risk. Radiation monitors will be placed in six onsite locations and will measure 24 hours a day, seven days a week, and be analyzed regularly. The plan approval also requires that a third-party conduct an audit inspection of the leachate pre-treatment and evaporation system every 12 months. Audits would include a full system inspection, cleaning, instrument calibration, training of operating staff, operator certification, and system restoration as needed. On Nov. 1, DEP executed a consent order and agreement that also requires Westmoreland Sanitary Landfill to take extensive proactive measures to detect, correct, and prevent future violations. Supporting documents as well as additional permitting and compliance information are available on the DEP’s community information webpage for Westmoreland Sanitary Landfill.

If reading that headline gave you a “déjà vu all over again” sort of feeling, it’s probably because the issue of the Clairton Coke Works air quality operating permit – called a Title V permit – has been in the GASP and local enviro headlines a lot over the past two years. For better or worse – more on that below – the permit is back in the air quality headlines, and the Allegheny County Health Department (ACHD) is seeking public comment on a few specific portions of the 311-page document. ACHD is also hosting an opportunity to provide testimony at a public hearing slated for 6 p.m. Wednesday, Jan. 10 at the Clairton Municipal Building. GASP will be in attendance to testify and stand in solidarity with residents and fellow advocates calling for accountability. We will also be submitting formal comments by the Jan. 18 deadline. We hope folks can join us Wednesday in Clairton to support our friends in the Mon Valley, who have suffered thanks to toxic emissions from their giant corporate neighbor. Head on over to the ACHD website to sign up to provide a public comment and/or get the skinny on how to attend the hearing. If you’d like a little more information on why this déjà vu redo happened in the first place and some details about the permit’s deficiencies, we’ve got you covered. Here’s what you need to know… QUICKLY, WHAT IS A TITLE V PERMIT? A Title V permit is a snapshot that includes all emissions limits and standards to which an emissions source is subject, as well as all operating, monitoring, and reporting requirements that apply at the time the permit is issued. By including all requirements in one document, these permits help source operators comply with those regulations. They also help regulators and members of the public enforce those requirements–all with the ultimate goal of reducing air pollution. GASP maintains a Title V permit clearinghouse, showing permits for sources in the area. If you’d like to learn more, check it out here. But it’s worth noting that Title V permits don’t create new rules or standards. We know the mishmash of cross-references in permits is anything but clear, but the permit needs to point to an existing law, regulation, court order, agreement, etc., for all its terms. HOW DID CLAIRTON COKE’S TITLE V PERMIT REAPPEAR ON THE RADAR? On Jan. 13, 2022, ACHD published a draft Title V permit open to public comment for U.S. Steel’s Clairton Coke Works. It was a long time coming: U.S. Steel applied to renew the permit in 2016. Many groups and individuals added their two cents, and after reviewing the input, on Nov. 21, 2022, ACHD issued the permit, but there were two more legal hurdles to clear before the permit was officially official. First, the US Environmental Protection Agency (EPA) had to review the permit and give its blessing to proceed with it as issued. In November 2022, the EPA did just that. Second, groups and individuals who commented on the permit but did not see the changes they expected had a right to appeal the permit. In March 2023, GASP did just that. Specifically, our petition argued that the Title V permit failed to include a compliance schedule, which is required by the Clean Air Act when a facility is out of compliance with emission standards or other permit requirements at the time a Title V permit is issued. Importantly, a separate petition filed by the Environmental Integrity Project (EIP), PennFuture, and Clean Air Council, argued that the Title V permit did not include monitoring and testing requirements sufficient to assure compliance with multiple air quality emissions limitations for many processes throughout the facility. This might strike you as a bit odd, but those petitions went to the EPA, the exact agency that in November 2022 already approved the permit. But give the EPA credit: In Sept. 2023, the agency issued an order granting almost all of the groups’ claims related to testing, monitoring, and reporting requirements as well as GASP’s claim regarding a compliance schedule. The order required ACHD to revise the Title V permit and/or the permit record in accordance with its decision, and just before festive season 2023, ACHD published a revised Title V permit for review. WHY THE TITLE V PERMIT NEEDS YOU First, there is a very important wrinkle to this comment period compared to others: ACHD is only interested in hearing input on the revised sections of the Tite V permit, not the entire permit. If you had your heart set on reviewing all 311 pages of the permit, sorry. Them’s the rules. On the bright side, ACHD documented every single change in a 25-page memo. It’s not light reading, but it’s not 311 pages. As for those changes, there are a lot of them, and many address the technical aspects of complying with the EPA’s order to ACHD. For example, U.S. Steel must now monitor the oxygen content of the Boiler No. 2 flue gas within 3% of the measured value and be recorded to the nearest 0.1%. That might be a bit in the weeds to address in the three minutes speakers are allotted at public hearings, but if you’re up for it, have at it. GASP will be focusing on the compliance plan EPA ordered ACHD to create because we’re pretty sure ACHD didn’t do what the EPA put in its order. To summarize, the EPA told ACHD to: Identify specific non-compliance issues Come up with remedial measures designed to lead to compliance and Put U.S. Steel on a schedule for those remedial measures, including an enforceable sequence of actions with milestones The draft Title V permit has a new Compliance Plan Requirement, but there isn’t a clear statement of what processes at Clairton Coke were non-compliant. We appreciate that Clairton Coke is a large, complex facility, but ACHD could have at least listed the processes that led to U.S. Steel racking up nearly $15 million in fines over the past five years (and that’s just the fines related to the 2019 settlement, the 2022 pushing emissions order, and the h2s exceedances orders from 2022 and 2023). The compliance plan measures also appear to borrow heavily from OSHA regs, which we’re pretty sure already applied to the facility, and the milestones are a bit murky. Ultimately, the details of the compliance schedule also are bit too in the weeds to get into in three minutes, but the point we hope to make at the hearing is that ACHD must demand U.S. Steel clean up its act. The law is clear: If U.S. Steel wants to make coke in Clairton, there must be a plan to get the full facility fully compliant with applicable requirements.

The state Department of Environmental Protection (DEP) this week announced that the Beaver County Environmental Mitigation Community Fund steering committee has finalized a protocol implementation plan, which establishes the advisory board’s role in executing projects and that applications are now being sought. By way of background: The $5 million Environmental Mitigation Community Fund was created as part of the consent order and agreement (COA) signed between DEP and Shell Chemicals Appalachia LLC. Under the agreement, Shell formally acknowledged that the company exceeded total emission limitations for air contaminants, agreed to make repairs to reduce future exceedances, and agreed to pay nearly $10 million to DEP and the local community – including $5 million for environmental projects to benefit the local communities. The plan also names The Pittsburgh Foundation as the trustee to manage and disburse the funds. The Beaver County Environmental Mitigation Community Fund advisory board is composed of representatives of organizations serving Beaver County and those spearheading environmental justice within DEP that recommend community project applications for selection and award funding. Information on the community fund, permitting, and compliance information is available on DEP’s community information webpage for the facility: dep.pa.gov/Shell. The application period for community projects to benefit the environment, health, and/or quality of life for communities in Beaver County will run through Feb. 29. A link to the application and more information can be found on DEP's community information webpage for the fund. A few necessary details: There is no minimum or maximum funding level, so applicants may apply for funding at an amount appropriate for their project. If funds are still available, there may be more application periods opened and projects funded. At least one project selected for funding should provide for regular, independent air quality testing in the vicinity of the facility. Also, at least one selected project should focus on meaningful community education and engagement that fosters civic participation. Projects that meet this criteria are encouraged. Eligible organizations must be classified as a 501(c)(3) or partner with one and be based in Beaver County or partner with a Beaver County-based organization. The advisory board will host two in-person public meetings, one virtual public meeting, two virtual question-and-answer sessions, and weekly virtual office hours. The virtual office hours will provide guidance and answer questions for prospective applicants. Dates, times, locations or log-in details will be posted on DEP’s community information webpage for the fund. Editor's Note: Stay tuned! GASP continues to follow this issue and will keep you posted as the process proceeds.

January is National Radon Action Month, marking a time of increased outreach and public awareness for this serious health hazard. What’s Radon & Why Should I Care? Radon is a colorless, odorless, radioactive gas that occurs naturally through the breakdown of uranium in soil and rocks. It can seep into homes through cracks in basements and foundations, then build up inside to concentrations many times the recommended level. It’s also the second-leading cause of lung cancer in the United States after smoking. That’s why the Pennsylvania Department of Environmental Protection (DEP) is working with home builders, school districts, realtors, and other state departments to address radon issues. The Keystone State is particularly prone to elevated radon levels, and the only way homeowners can know for sure if they have a radon problem is to test their home. DEP recommends that all homes and public and private buildings get tested. The department notes that the best time to test is during the colder months when homes and buildings are closed and radon is most likely to be trapped and building up to higher levels. How Can I Test Radon Levels in My Home? Fortunately, the DEP and our friends at the American Lung Association are working to provide radon test kits to Pennsylvania residents who have not yet tested their homes for this dangerous gas. These free radon test kits are available throughout the Commonwealth from the American Lung Association (while supplies last). By way of background: Radon test kits are also available for about $20 to $30 at many home improvement and hardware stores, as well as from Pennsylvania-certified radon laboratories. Here’s how they work: Completed test kits are forwarded to a Pennsylvania-certified lab where the sample is analyzed, and the results are provided to the home or building owner. Depending on the results, a permanent radon mitigation system may be needed. Those typically cost between $800 and $1,200 and require minimal maintenance. Is Radon the Only Indoor Air Quality Issue I Should Be Concerned About? Unfortunately, no, not by a long shot. There’s also asbestos, methane and other indoor air contaminants that impact your health and wellbeing. We encourage fellow breathers to attend GASP’s FREE upcoming Making the Connection virtual presentation on understanding common in-home environmental hazards. You'll gain valuable insights into identifying and minimizing environmental hazards in your home. Our expert speakers will cover topics such as indoor air quality and exposure to asbestos, lead, and radon. You'll learn practical tips and strategies to create a safer and healthier living environment for you and your loved ones. We'll focus on issues relevant in our region. Don't miss this opportunity to enhance your knowledge and take proactive steps toward a safer home - you can register here. Our panelists include: Rhett Major, The Energy Doctor and inspector Heath Papinchak, MPH, PhD, CPI, Welcome Home Inspections Nesta Bortey-Sam, PhD, Assistant Professor, Environmental and Occupational Health, School of Public Health, Pitt Editor’s Note: We also encourage folks concerned about their indoor air quality to check out our friends at ROCIS. The group has a FREE low-cost monitoring project starting soon. Check it out and sign up here.

Can we get a little cheesy? Just for a minute? As the year draws to a close, many of us reflect on the things we're grateful for. Here at GASP, we’re grateful for YOU. Because thanks to YOUR support, we can continue to show up and do what we do best: Be a vigilant watchdog, progressive policy advocate, and unwavering supporter of frontline communities. As yinz know (especially those who grapple daily with pollution from industrial bad actors), clean air - while a right - has not been a given for the Pittsburgh region generally and the Mon Valley specifically. And improvements to our air quality haven’t come easy. It’s taken tireless advocacy, unparalleled collaboration, and unwavering dedication - all things we’ve prided ourselves on for more than 50 years. GASP staff shows up every day and takes VERY seriously its role as our region's leading clean air watchdog, fighting for the health and well-being of our communities. But as we’ve said, air quality advocacy has long been a David vs. Goliath-type endeavor. Fortunately, members like you have had our backs. Your donations have helped level the playing field since 1969. As we get ready to close the books on 2023 and jump into the new year, we want to remind you that your tax-deductible, year-end donation can do so much good and is so appreciated. Here's why your year-end donation to GASP matters: We make a direct impact on air quality: GASP's work has led to significant improvements in air quality across the region, reducing harmful pollutants and protecting the health of our neighbors. We amplify the voices of frontline community members and their lived experiences: GASP works tirelessly to ensure that all voices are heard, especially those most impacted by air pollution. We empower the next generation of air quality champions: GASP's educational programs equip young people with the knowledge and tools to become environmental changemakers. Please know that your year-end donation to GASP is an investment in the health and well-being of your community. Every dollar you contribute helps us: Hold polluters accountable: When necessary, GASP takes legal action against regulators and members of the regulated community that violate air quality regulations, ensuring they are held responsible for their actions. Advocate for clean air policies: GASP works with policymakers at all levels to fight for stronger regulations to protect air quality. Educate the public: GASP provides educational resources and programs to empower people to take action for clean air. So this year-end, your pals here at GASP are asking you to give the gift of clean air. Your tax-deductible donation to GASP will make a real difference in the lives of people in your community. Here are ways you can donate: Visit GASP's website: https://www.gasp-pgh.org/donate Mail a check to GASP at 1133 S Braddock Ave Ste 1a, Pittsburgh, PA 15218 Donate by phone: (412) 924-0604 Onward and upward, The GASP Team

Did you hear? Allegheny County on Monday announced the first cohort for its Indoor Air Quality Improvement pilot program with 20 childcare programs in environmental justice communities. Here’s what’s going on: The goal of the pilot is to reduce the spread of respiratory infections and viruses through ventilation improvements. The pilot will also monitor whether changes reduce the frequency and severity of asthma flares in children, and if children's program attendance rates improve. The cost-free pilot was initiated through a partnership between the state Department of Children Initiatives and the Allegheny County Health Department (ACHD). The $462,000 pilot is funded through ACHD's COVID-19 Emergency Action Fund and a PA-DOH grant. Because of the variable nature of the physical locations and the varied solutions the cost per childcare facility will vary. The engineering firm Stantec is evaluating the centers to help identify the best solution for each physical space - whether that means improving ventilation systems or installing plug-in HEPA filters. In total, 76 facilities applied to be part of the pilot opened for application on Aug. 17. In early September, 20 providers were selected. The pilot measures impact through child care infectious disease tracking (before and after) and the number of days children are absent due to chronic respiratory illnesses. The departments hope the pilot can demonstrate success and be used as a state-level model to support regulated childcare facilities in improving air quality, particularly for children with chronic respiratory illnesses like asthma. The data will be tracked for a year, hoping to continue if the pilot is extended beyond its June 30, 2024 end date. Some good news: Funds are expected to be available in 2024 for other participants. The first cohort includes the following facilities:

Earlier this year we blogged about EPA’s proposed revisions to the National Emission Standards for Hazardous Air Pollutants for coke-making facilities (including the ones nearby in Clairton and Monessen) and integrated iron and steel manufacturing facilities (including the Edgar Thompson Works in Braddock). While those revisions have not yet been finalized, they have come under attack from a group of United States Senators, both Democrats and Republicans, including Pennsylvania’s own Senator Bob Casey, Jr. You can read the Cleveland Plain Dealer’s report about the letter (which contains a link to the letter itself) here, but this quote from the letter is its gist: We have serious concerns with these proposed rules because they would dramatically undermine the domestic steel industry and national security while driving production overseas likely resulting in no net reduction in emissions from the steel industry globally. Reducing the emission of harmful air pollutants should be done based upon sound science and with proven technology that is both technically and economically feasible. “The Senators do not describe how EPA failed to base its proposed revisions upon ‘sound science and … proven technology that is both technically and economically feasible,’” GASP senior attorney John Baillie said.  “Nor do they acknowledge EPA’s own extensive findings regarding the proposed revisions’ technical and economic feasibility or the benefits to Americans’ health that would follow the revisions.” GASP encourages folks to let Sen. Casey know how you feel about this here.

Children in the United States spend nearly seven hours a day, 180 days a year at school and while districts both public and private have many obligations to keep students safe, we want to talk about one intended to safeguard the air they breathe while there. One of the indoor air quality hazards school districts are required to monitor and manage is asbestos. What is Asbestos & Why is it Harmful? Asbestos is the name of a collection of silicate minerals used in many products throughout the 20th Century because of its strength and resistance to heat - we’re talking everything from cement to shingles. When asbestos is left undisturbed it does not pose a health risk. During renovation or demolition, however, it’s common for old, brittle asbestos products to release tasteless, odorless, microscopic fibers that can remain suspended in the air and enter your lungs when you inhale. Once inhaled, asbestos stays there forever. ​ Exposure to airborne asbestos can cause serious health issues including asbestosis, lung cancer, mesothelioma, and pleural disease. There is no safe minimum level of exposure to asbestos. It can take 20-40 years for some of these diseases to manifest, so we are currently seeing the results of exposures from the 1980s and 1990s now. The only way to be sure whether a material contains asbestos is to have it tested by a qualified laboratory. The EPA & Asbestos Hazard Emergency Response Act The Asbestos Hazard Emergency Response Act (HERA) was developed in 1986 after Congress acknowledged that because of a lack of federal regulatory guidance about asbestos abatement “some schools have not undertaken response action while many others have undertaken expensive projects without knowing if their action is necessary, adequate, or safe.” HERA requires school districts - both public and private - to take certain actions related to the maintenance and removal of asbestos containing material in their buildings. It should be noted that these regulations are founded on the principle of so-called in-place management of asbestos since removal is not usually necessary unless it’s severely damaged or is expected to be disturbed during renovation or demolition activities. HERA stipulates school districts must: Perform an original inspection of its school buildings to determine whether asbestos containing material is present. Conduct reinspections every three years afterward. Develop, maintain and update an asbestos management plan. Make available that management plan to the public within five days of being requested, and send annual updates about any abatement actions undertaken and/or planned. Designate a contact person trained to ensure that the school is meeting its obligations under the act. Perform periodic surveillance of asbestos-containing materials. Provide custodial staff with specific asbestos-awareness training. Ensure that only trained and licensed professionals perform inspections and abatement activity. Understanding School Asbestos Management Plans School districts are required to create plans and document recommended asbestos response actions, the location of the asbestos within the school, and actions taken to repair and remove the material. In addition, districts must maintain these records and include them in their plan: The name and address of each school building and whether it has asbestos-containing building material, and the type of asbestos-containing material The date of the original school inspection The plan for re-inspections A blueprint identifying the location of remaining asbestos-containing materials in the school A description of response actions and/or preventive measures taken to reduce asbestos exposure A copy of the analysis of the building, and the name and address of laboratories that sampled the material The name, address, and phone number of the designated asbestos contact A summary of steps taken to inform school stakeholders (parents, employees, students) about inspections, re-inspections, response actions, and periodic surveillance GASP’s Asbestos Ask We hope parents, students, and community members stay engaged on important public health issues like indoor air quality in our public and private institutions and seek out information about what YOUR local school district is doing to protect their communities from asbestos exposure. Please reach out to your local district and request information on their designated asbestos management contact, their management plan, and the required annual disclosures on these issues. When you do, please let us know how it goes - you can email our Program and Education Manager Laura Kuster at laura@gasp-pgh.org. Finally, please share this information with fellow members of your school community so they, too, can stay informed and engaged. “Letting school administrators and board members know this is important to you helps ensure this crucial public health issue remains on their radar,” GASP Executive Director Patrick Campbell said. “We hope you continue to show up when it comes to indoor air quality and how we can better protect our children and greater school community.” Editor’s Note: Check out GASP’s Asbestos Awareness page here for more information and resources.

Everyone deserves clean air, but sadly, too many of our neighbors struggle to breathe all too often thanks to industrial emissions from facilities like U.S. Steel’s Clairton Coke Work, which is one of the largest coke-making facilities in the country and one of the most egregious air polluters in the county. That’s why the Group Against Smog and Pollution (GASP) petitioned the EPA to reject the air quality permit the Allegheny County Health Department (ACHD) issued to U.S. Steel because it lacked a compliance schedule and other remedies to ensure the plan’s compliance with clean air laws. The EPA’s decision to grant our objections has provided an opportunity for residents to voice their views and share their experiences with industrial air pollution from the mill. That’s why the GASP is teaming up with our friends at the Black Appalachia Coalition on a petition demanding ACHD host educational sessions as well as a public hearing in Clairton related to efforts to get air pollution poster child U.S. Steel’s Clairton Coke Works back into compliance with air quality regulations. Here’s what we are petitioning ACHD to do: Championing environmental justice requires meaningful input from the people whose health and quality of life will be most impacted by operations at U.S. Steel's Clairton Coke Works. It is imperative that ACHD Air Quality Program leadership not only commit to hosting a public hearing regarding any proposed changes to the permit but also to convening an educational session in Clairton. This type of meeting would allow residents there to better understand the permit and how - and why - they should participate in the public comment process. While formal hearings allow residents to provide comments, they do not allow conversation and interaction between officials and residents. Sign this petition to urge ACHD to provide this important opportunity for public engagement and input. “We’ve said it before: The health department needs to build trust with the community and it can’t do that without transparency and accountability,” GASP Executive Director Patrick Campbell said. “Hosting a public hearing and educational sessions in Clairton is a first step to building back that lost trust.” No matter if you’ve been impacted by emissions issues at U.S. Steel’s Clairton Coke Works personally or simply want to stand with those who have been. we encourage you to check out and sign the petition here.

Dear Fellow Breathers, At GASP, we know that action is eloquence. So we won’t try to impress you with fancy prose because our work speaks for itself; work that helped drive real change here in southwestern Pennsylvania. For the past 54 years, we’ve taken a three-pronged approach to improving regional air quality, one that includes a mix of education, policy, and legal/watchdog work. On the education front this year we: Commenced our 3rd year of Fresh Voices for Clean Air - a program pairing Allegheny Co. high schoolers with peers in Birmingham, Alabama to elevate youth voices & support the next generation of environmental advocates. Partnered with myriad municipalities to educate officials about all things air quality so that they can more effectively serve their communities. Launched an asbestos-awareness campaign so folks understand it is still a clear and present air quality danger. On the policy front we: Helped launch a co-op in Allegheny County that helped residents and small business owners install solar panels for the best possible price. Joined Mayor Ed Gainey, state officials & fellow advocates to urge robust public support for zero-emissions vehicles and investments in clean transportation. Championed DEP’s draft Environmental Justice Policy and called on the department to go all-in on transparency. In the legal/watchdog arena we: Successfully challenged U.S. Steel’s Clairton Coke Works Title V permit, forcing ACHD to include a valid air quality compliance schedule to ensure air quality obligations are met. Pushed ACHD to increase public access to air quality data that helped lead to the creation of interactive dashboards displaying H2S and other important emissions inventory data. Started work on a multi-year air quality monitoring project funded by the EPA that will help fill gaps in the regulatory monitoring network and allow residents to better understand what’s in the air they breathe. The momentum is real, and we hope we can continue to depend on you to help us keep up the pace. To our longtime supporters: Thank you and please consider renewing your membership today. For those new to the GASP crew, please join us. Memberships start at just $50 – or an amount comfortable for you. Membership to GASP gets you weekly Alerts and invites to special events and our members give us standing to intervene in air pollution-related legal cases when necessary. You can make a one-time or recurring donation by visiting gasp-pgh.org/donate. Note: Many employers (like Google and BNY Mellon) match employee donations to nonprofits like GASP so you could possibly double your impact just by reaching out to your human resources representative. THANK YOU! Sincerely, Executive Director Patrick Campbell & President Jonathan Nadle