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- GASP Statement on Shapiro Tapping Allegheny County Health Dept’s Dr. Bogen for PA Health Secretary
Gov. Elect Josh Shapiro on Wednesday announced he nominated Allegheny County Health Department Director Dr. Debra Bogen as Pennsylvania’s next Secretary of Health. You can read more about the nomination announcement here. Allegheny County Chief Executive Rich Fitzgerald tweeted a statement about the nomination earlier today: No further information was immediately available regarding when Bogen may exit her ACHD post. Stay tuned, we’ll keep you posted. In the meantime, here’s GASP’s statement on the news: We thank Dr. Bogen for her service and wish her the best. We hope the County leaders will install a new director dedicated to improving air quality, community engagement, and improving the health of all county residents.
- Health Department to Residents: Data Shows E. Palestine Emissions Not Impacting Local Air Quality
The Allegheny County Health Department on Thursday issued a public update on its website and social media channels telling residents that it continues to monitor air quality in the wake of the East Palestine train derailment and that data has not indicated that emissions from the incident are a threat to local residents. Here’s what ACHD published: The U.S. Environmental Protection Agency (EPA), Pennsylvania, Department of Environmental Protection (PA DEP) and Ohio Department of Environmental Protection (Ohio EPA) have been on scene monitoring air quality since the train derailment. These agencies have not indicated that there are levels of volatile organic compounds (VOCs), hazards air pollutants (HAPs) or criteria pollutants from the train derailment in concentrations that would pose a threat to air quality in Allegheny County. With more than 25 miles from East Palestine to the county border, the ability for these emissions to disperse before reaching the county is very favorable. The county’s air quality monitors can detect several of the pollutants from the train derailment, like benzene and vinyl chloride. The Air Quality Program will continue to work with state and federal partners to monitor the situation and provide relevant updates to residents if needed. The most up-to-date Allegheny County air quality data is shown in the dashboard below. To learn more about the data we monitor, visit our monitored data webpage. For anyone seeking additional information, GASP recommends: The EPA’s official incident response web page. It is simple but dedicated solely to sharing information about the East Palestine train derailment and contains periodic updates, summaries of air monitoring data, important links, and other resources. This story from the Pittsburgh Post-Gazette. It provides in-depth info on what you need to know about air pollutants from the site and associated health concerns. Twitter handles for local reporters Reid Frazier and Kristina Marusic. Both have been covering the derailment and environmental and health concerns related to the explosion and its aftermath. This recording of last night’s town hall meeting in East Palestine.
- LIMITED (FREE) OPPORTUNITY | Attend Smoke School; Get the Same Training as the Health Inspectors
Even those of us who don’t live nearby to - or downwind of - an industrial source of air pollution like the Clairton Coke Works have at some point likely looked at emissions being belched from a facility and asked, “Is that even permitted?” You can learn the answer to that question and more at an upcoming smoke reading course. Never heard of smoke reading? Here’s what you need to know: 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. “Many are surprised to learn that 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 may help increase regulatory scrutiny on those neighborhood industrial plumes.” Sound like something you or someone you know would be interested in? Then we have good news for you: Allegheny County Health Department (ACHD) is covering the cost of the training by Eastern Technical Associates – but please know spots for this opportunity are extremely limited. The next training is scheduled for late March. 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 March 29 or March 30. 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.
- North Side Developers Appeal $754K Fine for Asbestos; GASP Calls for Increased Asbestos Education
Editor's Note: The Allegheny County Health Department on Feb. 21 filed a motion to dismiss the appeal. You can read that document here. A quartet of companies has appealed a $754,600 civil penalty assessed by the Allegheny County Health Department (ACHD) late last year for asbestos-abatement violations alleged to have occurred during a 2019 building renovation project involving 49 residences across Pittsburgh’s North Side neighborhood. The companies - Mistick Construction, Northside Properties Residence II, Northside Associates, and Tom Mistick and Sons - in their Jan. 13 appeal argue that the properties for which they were assessed penalties are not subject to Allegheny County’s asbestos abatement regulations and that ACHD improperly calculated the civil penalty. The appeal asks for the Allegheny County Health Department hearing officer to reject the enforcement order outright or reduce the civil penalty to no more than $12,000. But there’s a lot more to this story - and Allegheny County’s asbestos issue generally - so let’s take a step back and see how this whole thing started (and talk more about why abatement cases like this are concerning to GASP). ACHD’s Enforcement Order In May 2019, the companies were in the midst of the second of a multi-phase renovation project that “concerned no fewer than 49 individual properties located in the North Side.” Acting on a citizen complaint, ACHD investigated the project and determined that renovations had taken place at the residences without first conducting a thorough inspection to determine the presence of asbestos (the “asbestos survey” rule). ACHD issued stop-work orders on June 11, 2019. A month later, ACHD and the companies entered into a consent agreement that established a process for lifting the stop-work orders on a structure-by-structure basis. Each individual property was to be tested for the presence of asbestos, and, where necessary, cleaned and cleared by final inspections conducted by ACHD inspectors. On August 21, 2019, ACHD cleared the last structures that were subject to the stop-work orders, having discovered the presence of asbestos in renovation dust and debris in six of the 49 structures. Ultimately, ACHD’s Dec. 22 order imposed $754,600 in penalties against the companies for: Failing to perform an asbestos survey prior to renovation Failing to obtain an asbestos abatement permit Failing to adhere to asbestos work practices Reopening the work area to the public without a final clearance inspection and Failing to follow asbestos disposal procedures The companies appealing this fine admitted “a trace of asbestos was detected” in six residences but raised numerous issues with ACHD’s approach to calculating the fine. No matter how this case turns out, GASP is deeply concerned that these cases keep happening. The rules have changed over the years but it’s worth pointing out asbestos was one of the first hazardous air pollutants regulated under the Clean Air Act, with regulations covering demolition and renovation established in 1973. How Asbestos Harms Your Health When asbestos is left undisturbed it does not pose a health risk but during renovation or demolition, it’s common for old, brittle asbestos products to release tiny fibers that become airborne. These tasteless, odorless fibers can remain suspended in the air and enter your lungs when you inhale. Once inhaled, asbestos stays there forever because its chemistry keeps it from breaking down in the body. Exposure to airborne asbestos fibers can cause serious health issues including asbestosis, lung cancer, mesothelioma, and pleural disease. And there is no safe minimum level of exposure to asbestos. The World Health Organization estimates that 100,000 people die from asbestos exposure each year. It can take 20-40 years for some of these diseases to manifest, so we are currently seeing the results of exposures from decades ago. Asbestos exposure is the only known cause of mesothelioma and health officials say the mortality rate for mesothelioma in Allegheny County is “significantly higher” than that of both Pennsylvania and the nation. Unfortunately, asbestos-containing material (also known as ACM) was used in residential and commercial settings for decades, even after the carcinogenic effects of this fiber became apparent in humans. It’s commonly found in tile flooring, shingles, cement floors, insulation, and fireplace flues. In the 1980s, asbestos was partially banned in the United States in new building materials but some products are still permitted to use small amounts of asbestos. About the Allegheny County Air Pollution Regs Meant to Protect Us Allegheny County Health Department rules require an asbestos survey - a thorough inspection to determine the presence of asbestos - for all renovation and demolition projects. Demolition or renovation activities performed for a private homeowner of a residential structure with four or fewer dwelling units are exempt from the asbestos regulations, but not if the structures are part of a larger installation or project. Depending on the quantity of ACM identified, proper notification, specific work practices, and proper disposal of asbestos-containing material are required. 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. ACHD produced a very informative fact sheet about the requirements available online here. Why GASP Continues to Sound The Alarm Over Asbestos GASP remains concerned about the volume - and severity - of asbestos-abatement enforcement cases in Allegheny County. We already know Allegheny County is a hotspot for asbestos exposure, that our area is ripe with aging infrastructure and buildings, and that revitalization efforts in some of our most vulnerable environmental justice communities involve demolition and rehabilitation of blighted properties. “We hope we can work with the Allegheny County Health Department to help educate the public about the rules and regulations covering asbestos,” GASP Executive Director Patrick Campbell said. “We also hope ACHD will consider forming a subcommittee to examine the current processes associated with asbestos abatement permitting to determine what steps can be taken to improve them and ensure increased compliance.” He continued: “We know this is a huge issue - the Air Quality Program has told us its downright overwhelming. We think it’s time ACHD tries addressing it differently, and GASP is committed to helping any way we can.” In the meantime, GASP is crafting educational content for residents and contractors to better understand and access information related to asbestos abatement in Allegheny County. Stay tuned. Editor’s Note: You can read ACHD’s enforcement order for yourself here. The associated appeal can be viewed here.
- Rotten Egg Stench & Poor Air Quality Return to Mon Valley
Local residents took to CMU CREATE Lab’s Smell PGH app Monday morning to sound off about poor air quality and its associated stench, conditions they said caused physical symptoms like itchy eyes, burning throats, and headaches. Although concerns persist about potential local impacts from the East Palestine railroad derailment, this most recent spate of bad air quality appears to us to be centered in the Mon Valley and follows a pattern we’ve seen too many times before: high levels of fine particulate matter (PM2.5), hydrogen sulfide (H2S, which has a tell-tale rotten egg odor) and sulfur dioxide (SO2) building in the overnight hours. Concentrations of H2S at Allegheny County Health Department’s (ACHD’s) air quality monitors in Liberty and North Braddock boroughs exceeded the state’s 24-hour average standard of 0.005 ppm this morning shortly after midnight. Exceedances of this standard also occurred several days last week. A quick word about H2S: It’s a colorless gas recognizable by its rotten egg odor and the concentrations we see in the Mon Valley can cause irritation to the eyes, nose, or throat as well as headaches, poor memory, tiredness, and balance problems. It may also cause difficulty in breathing for some asthmatics, according to the Agency for Toxic Substances and Disease Registry. In the overnight hours, there were also exceedances of the national health-based standard for SO2 at ACHD’s air quality monitor North Braddock. The standard is an hourly level of 75 parts per billion (ppb); ACHD reported levels of 83 ppb and 97 ppb Sunday and Monday. “At a time when the public is understandably on high alert when it comes to air quality because of the horrific rail crash in East Palestine, we can’t overstate how important it is for our local health officials to help residents understand our local conditions,” GASP Executive Director Patrick Campbell said. “We’ve been urging the department to ramp up its public communications around air quality issues, and while we have seen some uptick, GASP is again calling on ACHD to provide proactive and robust public communications so residents are better equipped with the information they need to mitigate health impacts.” Editor's Note: For those who'd like to take a deeper dive into the data, we graphed the PM2.5 and H2S concentrations. Check it out:
- U.S. Steel, ACHD Trade Barbs Over Coke Oven Enforcement Procedures; GASP: As They Bicker We Suffer
The Allegheny County Health Department and U.S. Steel traded barbs over the past few weeks in legal filings addressing evidentiary issues in a pending case addressing enforcement procedures ACHD uses to assess penalties at the steelmaker’s Clairton Coke facility. To make a long story short: Following the filing of U.S. Steel’s initial dispute resolution petition last month demanding certain fines be vacated due to air quality inspectors improperly conducting emissions opacity readings (allegedly), ACHD filed objections to the company’s reliance on video evidence it said was recorded in “bad faith” and that was not in keeping with guidance on emissions opacity readings. U.S. Steel in return made its own request to the hearing officer, asking in a filing this week that the department’s objections be dismissed because ACHD was misapplying court rules and attempting to paint the company in a “bad light.” “‘How opaque is that smoke, really?’ That’s it. That’s the issue. And even after ACHD and U.S. Steel entered into a Settlement Agreement in 2019 designed to – among other topics – address the opacity issue they are still arguing in 2023,” said GASP staff attorney Ned Mulcahy. He continued: “It’s shameful. It’s a waste. And while a corporate ‘good neighbor’ and government officials bicker, community members still endure poor air quality entirely too often.” While we wait for the next installment in this ongoing air quality case, you can read the initial petition here, ACHD’s objections here, and U.S. Steel’s most recent filing here. GASP continues to follow the issue and will keep you posted as it proceeds.
- #ICYMI: EPA Orders Neville Scrapper to Reduce Emissions, Limit Hours Following Years of Complaints
The U.S. Environmental Protection Agency (EPA) recently ordered a Neville Island-based metal scrap facility that’s long been the subject of local residents and environmental advocacy organizations’ air quality complaints to reduce emissions and limit its hours of operations. The news was first reported by WESA’s Reid Frazier. Here’s an excerpt from his Feb. 8 story: Neighbors have reported periodic explosions and fires at the plant, which boasts on its website of shredding 6,000 cars a month. The shredding can result in fires and smoke because the cars may still have fuel and other flammable material in them, Taranto said. As a result, residents have complained about smoke, sound, and the smell of burning plastic. “It’s been extremely disruptive, particularly for those that are right close to the river,” (Angelo Taranto, of Allegheny County Citizens for Clean Air Now, or ACCAN) said. “It makes people sick. They have to close up their houses in the summer. They can’t let their children out when the odor and the smoke is heavy.” The EPA consent order limits the company to operating for a maximum of 10 hours per day, or eight hours during an air quality action day, when pollution levels in the region are forecast to exceed federal health standards. It also sets production limits for the scrap shredding at the plant of no more than 120 tons per hour, or 240,000 tons per year. The order set a limit on air pollution of no more than 50 tons per year of volatile organic compounds, airborne chemicals that form smog. And it sets additional reporting requirements for the plant. We encourage folks to read Mr. Frazier’s full report here and be sure to follow our friends at ACCAN for more information and action items related to this issue. ACCAN has been leading the charge to demand action on Metalico for years. You can follow them on Twitter here and Instagram here. You can read the EPA’s administrative order here.
- PA Affordable Housing, PPG Paints Arena & Others Subject to Air Quality Enforcement Action, Fines
At GASP, we hope to be your eyes and ears when it comes to all things air quality. And we think it’s especially important to spotlight local air quality enforcement activity so residents can be aware of what types of infractions are taking place in their communities. That’s why part of GASP’s watchdog work includes monitoring and reporting on the air quality violations the Allegheny County Health Department (ACHD) periodically posts to its website. ACHD took enforcement action recently against: PPG Paints Arena (formerly Consol Energy Center) on Jan. 13 for failing to renew its minor source operating permit, which expired on Oct. 24, 2018. The enforcement order indicates that PPG Paints Arena officials have failed to respond to repeated requests for information related to its permit renewal. The Jan. 10 enforcement order states: PPG Paints Arena Representatives have failed to respond to four requests to submit their minor source renewal permit application. Additionally, PPG Paints Arena Representatives have failed to respond to two requests for required reports and other documentation. Furthermore, PPG Paints Arena Representatives are required to submit the requested application, reports, and documentation, regardless of whether ACHD Representatives requested them. PPG Paints Arena had seven days to respond to ACHD’s order. No further information was available on the ACHD website on this enforcement order, which can be read in full here. Pittsburgh Allegheny County Thermal, on Jan. 10 for failing to submit its Title V Certificate of Compliance, which was due on May 30. The enforcement order indicates the company submitted the certificate on Dec. 31 upon request from ACHD. ACHD assessed a $1,080 civil penalty for the records-keeping violation. You can read the full enforcement order here. The PA Affordable Housing Corp. on Jan. 10 for open burning violations for which it was assessed a $1,200 civil penalty. According to the enforcement order, the illegal burning took place at a residence the nonprofit owns located at 536 E. Garden Road in Brentwood. According to the order, PA Affordable Housing Corp. failed to burn only seasoned dry wood. The size of the fire also exceeded a volume of 3 feet x3 feet x2 feet high, which violates county regulations. ACHD also said PA Affordable Housing Corp. failed to have a responsible person on site tending the fire. Here’s what ACHD said happened: On Friday, June 3, 2022, ACHD Air Quality Representatives performed an investigation regarding open burning at 536 E. Garden Road. ACHD representatives found the Brentwood Fire Department on the scene extinguishing an oversized fire of logs and trash, approximately 10 feet width x 10 feet length x 2 feet height in size. During the discussion with the Brentwood police officer and fire department, the officials stated that they responded to a similar event on Wednesday evening, June 1, 2022, when they extinguished two oversized, unattended fires, one 6 feet x 6 feet and one 8 feet x 8 feet at the same address. According to the order, ACHD on June 9 visited the office of PA Affordable Housing and spoke with Shawn Taylor. Inspectors explained the visit was regarding an open burning complaint, showed him photos from the fires in question, and explained county regulations. PA Affordable Housing Corp. has 30 days to appeal the order. You can read the entire order here. ACHD also took enforcement action against three local companies for asbestos abatement-related violations. They include: Chanticleer Unit Owners Association and Burns & Scalo were issued a stop-work order Oct. 25, 2022, for failing to obtain the required asbestos survey prior to starting renovation work at a property located at 53 Highland Road in Bethel Park. ACHD ordered the companies to provide a “thorough asbestos report” by a licensed contractor, conduct testing of construction material to determine if asbestos-containing material was present, and provide waste manifests for material already removed from the site. Chanticleer Unit Owners Association and Burns & Scalo had seven days to submit the required documentation. No further information is available about the order, which can be viewed here. ACHD issued a warning letter to Kane Specialty Group on Nov. 28 advising the company that it was in violation of county asbestos-abatement regulations. According to the letter, the employee who oversaw the asbestos abatement at 1817 Banksville Road failed to maintain his asbestos building inspector/supervisor license, which had expired in October 2022. You can read the warning letter here. A similar warning letter was issued to Todd Cioppa, Vasyl Khymiak, and their company Titon Holdings for violating the county’s asbestos-abatement regulations. During an inspection of renovation work completed at 300 Sixth Ave Pittsburgh, ACHD determined that Cioppa and Khymiak were not certified by the state Department of Labor and Industry; their licenses expired in October 2022. Editor’s Note: You can learn more about asbestos and Allegheny County Health Department’s abatement regulations here.
- The U.S. Steel Edgar Thomson Emissions Consent Decree Explained
As GASP reported Monday, like it or not, U.S. Steel’s Edgar Thomson facility is now subject to the terms of a court-approved consent decree entered into by the company, the Allegheny County Health Department (ACHD), the Department of Justice (DOJ), and the Environmental Protection Agency (EPA). The goals of the consent decree are to resolve various issues at Edgar Thomson that led to a joint enforcement action between EPA and ACHD against U.S. Steel in 2017 and ensure the facility complies with applicable air quality laws and regulations going forward. The decree itself spells out a series of measures U.S. Steel must take to meet those goals. GASP staff reviewed the final agreement and put together a summary of what it requires in plain English: Pig Iron, Casting Slabs, and the BOP Shop (a quick rundown of the terminology you’ll need to understand first) U.S. Steel’s Mon Valley Works is what is known as an integrated steelmaking operation. That means U.S. Steel starts with raw materials – iron ore, coal, etc. – and produces finished steel. The Edgar Thomson facility makes molten iron (or pig iron) in its blast furnaces using coke from Clairton, iron ore, and other materials. Within the blast furnace casthouses, the furnaces are tapped and the pig iron is collected in rail cars (called torpedo cars) for transfer. A molten sulfurous metallic waste product of the blast furnace is slag, which is diverted into open pits to cool before processing. The facility turns iron into steel by way of the basic oxygen process (BOP) in a part of the mill aptly named the BOP shop. Molten steel is poured into a continuous caster that creates steel slabs, which are then shipped by rail to the Irvin Works for finishing. We created a guide to the blast furnace and BOP shop locations with labeled photos you can view here. Consent Decree Terms Actions U.S. Steel must take fall into three broad categories: emissions reductions from specific processes, enhanced emissions monitoring, and enhanced equipment maintenance. Emissions The most immediate action required is that by Feb. 14, U.S. Steel must begin “feeding an oxidizing chemical additive or additives . . . into the slag pit quench water spray system, to enhance suppression of H2S emissions.” Within 90 days of starting that process – but by May 15 at the latest – the company is required to submit to the EPA and ACHD written procedures detailing how it will continue to reduce emissions from slag pit operations. U.S. Steel must also reduce emissions from the blast furnaces’ casthouse baghouse system, the BOP shop roof ventilation, and the BOP shop scrubber system. Unfortunately, these improvements won’t be in place anytime soon: U.S. Steel must first obtain independent engineering evaluations to identify potential emissions reduction improvements. The consent decree states, “U. S. Steel has retained and EPA, after consultation with ACHD, has approved” independent third-party contractors to conduct studies of all three systems. For all three studies, the contractors must submit detailed plans for conducting the studies that ACHD and EPA must then approve outright, approve with conditions, approve partially, or reject. Here is what the consent decree says about the timeline: The plan for the casthouse study was due Jan 15. The plans for the two BOP shop studies are due Feb 14. The studies must be completed within 120 days after they are approved, but when the approvals will be issued is anyone’s guess (there are no approval deadlines in the consent decree). U.S. Steel must submit copies of the final studies to EPA and ACHD within 90 days of their completion, along with a report that details improvements recommended by the third-party contractor and reasons why they should or should not be considered, cost estimates for proposed projects, and a schedule to complete the projects. Once again, after approval (however long that takes), U.S. Steel “shall implement the proposed actions” laid out in the schedule. Finally, U.S. Steel must submit to EPA and ACHD a notice of completion certifying that the actions were implemented in accordance with the approved plans. Given the unknown approval turnaround times, we can’t say for sure when these improvements will be in place. So far, ACHD has declined the invitation – via the public comment period – to establish a website where these documents could be posted and deadlines updated. Via public records requests, GASP hopes to update the public as work progresses. Monitoring By June 14, U.S. Steel must permanently install and maintain no fewer than seven video cameras aimed at problematic sources of visible emissions including the blast furnace stove stacks, casthouse roof monitors and baghouse, BOP shop roof monitor and scrubber stacks, and two staging areas for torpedo cars. These cameras will not be a way for regulators to determine compliance with air quality regulations. Rather, the decree states they will be used to keep a better eye on potential emissions sources so U.S. Steel can take “corrective actions to minimize or eliminate any such emissions as expeditiously as possible.” In addition to the camera system, by Jan. 15, U.S. Steel was to have ensured a third-party observer – trained and certified in accordance with EPA Method 9 – began conducting visible emissions readings covering the casthouse roof monitors, BOP shop roof monitor, and BOP shop scrubber stacks twice a week when the equipment was operating. You might recognize that the areas subject to Method 9 scrutiny are also the three areas with pending engineering studies (see above). That is intentional – this will help the EPA and ACHD be certain the upgrades measurably reduce emissions. In fact, within 30 days after U. S. Steel submits the notices of completion for the upgrades required in those studies, the Method 9 inspection frequency will increase to four days per week. This extra monitoring will end after four consecutive months of 100 percent compliance or 12 months from the start of the more frequent inspections (whichever is sooner). Both before and after the upgrades, the agreement requires U.S. Steel to provide information weekly on when and where the visible emissions readings will be taken to allow an ACHD staff member or contractor the opportunity to be present during the readings “and, as necessary, perform ACHD’s own observations to verify compliance.” U.S. Steel must generate a report for each Method 9 reading required by the decree and submit quarterly reports of its compiled Method 9 observations. These reports must identify any deviation(s) from the applicable opacity standards as well as the “likely cause of such deviations(s), corrective measure(s) taken to address the deviation(s), and the effectiveness of such corrective measures as can be determined at the time of the report.” Finally, by March 16, U.S. Steel must submit a monitoring plan to install a continuous SO2 monitor for the facility’s riley boilers. These boilers burn blast furnace gas, coke oven gas, and natural gas to generate steam, heat, and electricity for the plant. Maintenance A third-party auditor will conduct a maintenance practices audit that will analyze emissions control operations and maintenance practices for the casthouse baghouse, the BOP shop fugitive emissions baghouse, the BOP shop mixer baghouse, the BOP shop LMF baghouse, the BOP shop primary emissions system/BOP shop scrubber, and the slag pits. The auditor will have access to all records, employees, contractors, and areas of the facility deemed reasonably necessary to effectively conduct the audit. By June 14, the auditor must submit a report to U.S. Steel that includes: a summary of the audit process, including any obstacles encountered detailed audit findings, including the basis for each finding and each area of concern related to the adequacy of Edgar Thomson’s operations and maintenance plan for ensuring current and continued future functioning of emissions controls and compliance with applicable emission limitations information about whether requirements, targets, objectives, or other benchmarks are being achieved; whether there are examples of noncompliance with the operations and maintenance plan; and “recommendations for resolving areas of concern or otherwise achieving compliance with the operations and maintenance” A certification by the third-party contractor and U. S. Steel that the audit was performed in accordance with the proposed consent decree. Within 60 days of receiving the auditor’s report, U.S. Steel must submit that report to the EPA and ACHD along with a proposal for implementing any recommendations in the report. In addition to the third-party audit, U.S. Steel must undergo self-audits every 12 months and submit for approval plans to EPA and ACHD detailing everything from obstacles encountered to the adequacy of the operations and maintenance plan to whether required objectives and benchmarks are being met. Finally The consent decree requires U.S. Steel to submit to EPA and ACHD semi-annual reports detailing everything from the progress made on required upgrades and training to problems encountered and changes made to the facility’s operations or maintenance plans. Those reports must be submitted by Feb. 28 and Aug. 31 each year. Editor’s Note: GASP staff is following the consent decree issue - and deadlines therein - carefully and will keep you posted.
- Save the Date: Join GASP, Black Environmental Collective, WHE for Discussion on Environmental Racism
Environmental Racism is defined as a condition in which the places where people of color live suffer disproportionately from the impacts of air pollution, toxic waste, extreme weather, and other hazards. Environmental justice is defined as a condition in which fairer participation in decision-making removes these dangers. Mark your calendars and join us at 7 p.m. Feb. 19 for a panel discussion of these important issues, and how we work together to build a better, more equitable future for us all. The panelists for the event - hosted by the Social Justice and Outreach Committee, Episcopal Diocese of Pittsburgh, Pennsylvania Interfaith Power & Light, and Pennsylvania Interfaith Impact Network - will include: Black Environmental Collective Director Alyssa Lyon GASP Executive Director Patrick Campbell Women for a Healthy Environment Executive Director Michelle Nacaratti-Chapkis We hope you can make it to this important discussion. No registration is needed - just click here to join when it’s time.









