The U.S. Environmental Protection Agency (EPA) recently completed a risk assessment for commercial sterilizing facilities (they sterilize medical equipment and devices and more) that use the hazardous air pollutant ethylene oxide. The determination was startling: It found emissions of ethylene oxide from these facilities increase the lifetime cancer risk for the people who live near them. For the uninitiated: Ethylene oxide is a flammable gas with a somewhat sweet odor and in addition to increased cancer risk, exposure may cause myriad ailments, from headache, nausea, vomiting, and diarrhea to breathing difficulty, drowsiness, weakness, exhaustion, eye and skin burns, frostbite, and even reproductive effects. Now, like with so many other air quality issues, we now need to back up and explain a little bit of the process: The assessment was conducted because EPA is charged under the Clean Air Act with the duty of periodically re-assessing the health risks posed by emissions of hazardous air pollutants. As a result of this risk assessment, EPA will propose more stringent regulations governing ethylene oxide emissions from commercial sterilizing facilities later this year. Two commercial sterilizing facilities in western Pennsylvania are among those EPA found to contribute to an increased lifetime cancer risk to their neighbors: American Contract Systems, Inc., in Zelienople, Butler County, and Cosmed Group LLC/Erie in the City of Erie. EPA purportedly is working with the Pennsylvania Department of Environmental Protection (DEP) to review the emission controls already in place at these facilities and to determine whether new or improved emission controls are needed at the facilities. A GASP review of the operating permit for Cosmed Group shows it is already required to operate control equipment that removes ethylene oxide with at least 99 percent efficiency. “American Contract Systems, however, is apparently not subject to any air pollution control permits at this time – DEP’s eFACTS website shows the company just applied for its first plan approval on July 19, 2022, and that DEP is currently reviewing the company’s application for that plan approval,” GASP senior staff attorney John Baillie explained. He continued: “Why American Contract Systems does not appear in DEP’s database of air pollution control permits is a good question. It appears that the facility has been in operation since at least 2018, when the FDA found the facility was not complying with regulations governing the production of medical devices.” EPA will hold a national public webinar to provide more information to communities at risk from ethylene oxide emissions at 8 p.m. Aug. 10, 2022. GASP continues to follow this issue and will keep you posted as the regulatory process unfolds.

The Allegheny County Health Department this week quietly released an inaugural air quality report detailing work undertaken by the Air Quality Program over the past year, its goals moving forward, and how residents can stay informed and involved. Titled, 2021 Air Quality Annual Review: The Process of Progress the 32-page report begins with a personal message from Director Debra Bogen that notes some of the highlights from the past year including: The completion of a study that determined that U.S. Steel’s Clairton Coke Works was “entirely” responsible for years of hydrogen sulfide (H2S exceedances in the Mon Valley). The addition of the Mon Valley Air Pollution Episode Rule (you can learn all about *that* here). Increased enforcement and compliance efforts regarding asbestos abatement. “This work does not happen on its own,” Bogen wrote in her intro. “The ACHD relies on community engagement to improve the region’s air quality. We hope that you will join us in our efforts to improve the health of our current and future residents.” We encourage folks to check out the report, which can be viewed in its entirety here. In it, you will find details about ACHD’s air quality monitoring system and staff, as well as helpful information related to everything from how to make an air quality complaint and sign up to receive Allegheny Alerts to department funding sources and recent grants.

The U.S. The Environmental Protection Agency (EPA) announced last week that a Zelienople commercial sterilization facility was on a list of facilities that utilize a hazardous air pollutant known as ethylene oxide – a compound linked to an increased risk of cancer for the people who live nearby. You can read our blog detailing the announcement here. That blog noted that the company, American Contract Systems, was not subject to any sort of air quality permit from the state Department of Environmental Protection (DEP), and had just applied for its first air quality plan approval on July 19. We are pleased to report that in response to our blog post, a DEP representative reached out to us with additional information to explain why American Contract Systems was able to operate without such a permit. Because the facility uses less than 1 ton of ethylene oxide per year, it is exempt from the permitting requirements that exist under both the Pennsylvania air pollution regulations and the National Emission Standard for Hazardous Air Pollutants for commercial sterilization facilities that use ethylene oxide. And this is good news in light of EPA’s announcement and anticipated stricter regulations, American Contract Systems will voluntarily install pollution control equipment that is expected to reduce its existing emissions of ethylene oxide by at least 99 percent. As a reminder: The application for a plan approval that American Contract Systems submitted to DEP on July 19 was to authorize the installation of these new pollution controls. We expect and hope that the emission reductions will mean that American Contract Systems’ neighbors will no longer face an increased risk of cancer from its emissions of ethylene oxide. GASP thanks DEP for both the new details and its transparency.

Documents obtained through a public records request GASP submitted to the Allegheny County Health Department last month have provided new details about power outages at U.S. Steel’s Clairton Coke Works over the Fourth of July weekend – but also raise new questions about the condition of the facility’s electrical system. Yes, we said outages. Plural. As in there was more than one. As a reminder, ACHD on July 4 issued the following message through its Allegheny Alerts system: Today, July 4, at 5:30 a.m., the United States Steel Clairton Coke Works plant experienced a power outage that affected plant operations. Power was recently restored, and the facility is working to return to normal operations. The outage has required the flaring of coke oven gasses from the stacks and batteries. The Allegheny Health Department’s Air Quality Program has been monitoring its air quality monitors around the plant since the outage occurred. Area monitors have not indicated any adverse conditions since the event and it is believed that the power outage will either not affect or only minimally affect plant emissions. The Health Department will remain in contact with the plant throughout the day. GASP’s records request yielded seven documents and three voicemails related to two outages reported to ACHD by U.S. Steel – one on July 2 and the other on July 4. Here’s what happened… Breakdown Report #1: What We Know About a July 2 Outage at U.S. Steel’s Clairton Coke Works Facility U.S. Steel is required by its Title V Operating Permit and ACHD’s air pollution control regulations to notify ACHD immediately of any breakdown of pollution control equipment likely to result in the release of pollutants in violation of their permit or the other emission of toxic pollutants into the air and to follow up with a written report within seven days. A breakdown report submitted to ACHD by U.S. Steel dated 9 a.m. July 5 reveals that U.S. Steel experienced the first outage from 4 a.m. to 7 a.m. July 2 because of “electrical issues.” The report was brief: It noted the breakdown resulted in elevated sulfur in the coke oven gas and that the company was “working as quickly as possible to repair issue.” Under the section asking about measures taken during the shutdown, U.S. Steel provided a one-word answer: None. You can read that breakdown report here. Breakdown Report #2: What We Know About the July 4 Outage at U.S. Steel’s Clairton Coke Works Facility About 20 minutes after U.S. Steel submitted the breakdown report detailing what happened on July 2, ACHD received a second breakdown report stating that the company “lost all power” to the Clairton Coke Works around 5:30 a.m. July 4. Again, the report was brief, with U.S. Steel stating that it was “troubleshooting” and had “all hands on deck” to get the facility back online and that it was flaring coke oven gas at all of its batteries.” U.S. Steel went into further detail in two follow-up breakdown reports submitted on July 11 and July 12, telling ACHD that a power outage had affected operations in Control Rooms #1, #2, and #5. “The Clairton plan suddenly and unexpectedly lost power to the plant,” the report stated. In addition to flaring, U.S. Steel noted that it had also extended coking times. The report stated that no pushing or charging occurred during the outage. According to U.S. Steel, approximately 11.6 tons of sulfur dioxide were released during the 41-hour outage. If at this point you’re saying to yourself, “Wait, I thought the Allegheny Alert released by the health department the morning of July 4 said that power had been restored to the plant? I’m confused?” then you are not alone. An internal ACHD email, as well as correspondence between the department and U.S. Steel, show the health department was, too. In an email to Air Quality Program staff, one ACHD staffer wrote, “Are we pointing fingers that it is 10:08 a.m. on July 5 and I do not have anything saying it was back online? Did someone else receive this information and not tell me?” Then in a separate July 8 email exchange with U.S. Steel, ACHD asked the company to double-check and correct the date on the July 2 breakdown report. U.S. Steel then confirmed via email that the date was correct and that there had actually been two outages. All told, the power outage lasted for 41 hours – from 5:30 a.m. on July 4 through 10:30 p.m. on July 5. U.S. Steel provided three voicemail updates to ACHD as the outage continued. You can listen to the first voicemail here, the second voicemail here, and the third voicemail here. Why the Documents Raise More Questions Than They Answer It’s clear from recent history that “electrical issues” and general maintenance deficiencies continue to plague U.S. Steel’s Clairton Coke Works facility. Remember the Christmas Eve 2018 fire at the Clairton Coke Works that knocked key emissions reduction equipment offline for three months? Let’s not forget the cause of that fire, which was exposed in an award-winning, in-depth investigative report from Allegheny Front’s Reid Frazier: Eroded equipment and sub-par facility maintenance. If you don’t it's worth a read. We also want to point out that U.S. Steel is no stranger to electrical issues: Less than six months after that catastrophic fire, Clairton Coke Works’ pollution-control systems were again knocked offline thanks to an electrical fire that caused the closure of the same control rooms damaged on Dec. 24, 2018. They are also the same control rooms impacted by the July 4 outage – #1, #2, and #5. U.S. Steel’s maintenance and electrical issues haven’t just been the stuff of headlines, they have also been the subject of litigation. For the uninitiated: GASP staff took a deep dive into a federal class-action lawsuit filed in April 2019 against U.S. Steel on behalf of its investors. The complaint includes testimony from current and former U.S. Steel employees who were deposed as—and referred to in court documents—as confidential witnesses. Those confidential witnesses, one of whom worked at the Clairton Coke Works for 40 years, described systemic maintenance and operational failures at the plant. GASP staff then looked at U.S. Steel’s air emissions compliance by analyzing Allegheny County Health Department’s 2018 enforcement order related to the Christmas Eve fire, as well as court transcripts from the hearing related to U.S. Steel’s appeal of that order. That analysis showed that the company was struggling to comply with air emissions standards during the same period of time when the plaintiffs alleged U.S. Steel asked employees to “jury rig” machines and generally operated with a “don’t buy, get by” mentality. There is also an ongoing legal case against the company filed by PennEnvironment and Clean Air Council alleging that systemic maintenance failures led to the Christmas Eve 2018 fire at the Clairton Coke Works and that U.S. Steel should be charged with 12,000 violations of clean air laws. With all that said, here’s the bottom line: While both U.S. Steel and ACHD downplayed the July 4 outage, stating that impacts on ambient air quality were minimal and that there were no exceedances noted, they have failed to address what is being done to get at the root of the problem. So we are asking publicly to both ACHD and U.S. Steel these questions: Does the Mon Valley Works have a bigger electrical issue than officials have let on? What steps are being taken to prevent power outages like the ones that knocked pollution-control equipment offline from happening again? Were the July 2 and July 4 incidents connected? If so, had U.S. Steel taken action on July 2, could the second outage have been prevented? ACHD told residents the morning of July 4 that the plant was back up and running and that flaring had ceased when in fact that was not the case – the Coke Works did not come back online the evening of July 5. Why wasn’t an updated message sent to residents? “This seems like a case of ‘those who do not learn history are doomed to repeat it.’ ACHD inexplicably waited more than two weeks to tell Mon Valley residents that the Christmas Eve 2018 fire had occurred and that air quality was being impacted. The department rightfully was raked over the proverbial coals by community members and environmental advocates,” GASP Executive Director Patrick Campbell said. “ACHD had the opportunity July 5 to demonstrate its commitment to transparency and accountability and share updated information with residents to help them make more informed decisions about how to mitigate their risk and again they blew it.” He continued: “Instead, the department waited as long as legally possible to release any documents related to the incident. At this point we feel like a broken record but will say it once more a little louder: Residents deserve better from both the health department and U.S. Steel.” Editor’s Note: Stay tuned, this blog will be updated if and when we receive any further information.

The U.S. Environmental Protection Agency (EPA) is proposing revisions to the Risk Management Program (RMP) rule to further protect vulnerable communities from chemical accidents, especially those living near facilities with high accident rates. The proposed rule, titled the “Safer Communities by Chemical Accident Prevention Rule,” would strengthen the existing program and includes new safeguards that have not been addressed in prior Risk Management Plan rules, such as enhanced employee participation and transparency for communities on safety decisions. The Risk Management Plan rule protects public health and the environment by requiring industrial facilities with high accident rates to prevent accidental air releases of dangerous chemicals that could cause deaths, injuries, property, and environmental damage, or require evacuations in surrounding communities. This rule is a critical piece of EPA’s work to advance environmental justice as these facilities are often located in communities that have historically borne a disproportionate burden from pollution. Changes made to the RMP rule in 2019 were identified as an action for review under President Biden’s Executive Order 13990, “Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis.” The proposed rule would: Provide greater protections for communities living near Risk Management Plan facilities, many of which are underserved and overburdened by pollution. Promote environmental justice through increased availability of information for fenceline communities in their requested language. Require safer technologies and alternatives analysis for certain facilities with high accident rates. Advance greater employee participation and opportunity for decision-making in facility accident prevention requirements. Require third-party audits for facilities with a bad track record of accidents. Enhance facility planning and preparedness efforts. And YOU have an opportunity to weigh because the EPA will engage stakeholders during a public comment period. The public may comment on the proposed rule at www.regulations.gov (Docket ID No. EPA-HQ-OLEM-2022-0174) until 60 days after publication in the Federal Register. EPA is also holding three virtual public hearings on the proposed rule on Sept. 26, 27, and 28. For more information on the proposed rule: RMP Safer Communities by Chemical Accident Prevention Proposed Rule. For more information on the public hearings: Virtual Public Hearings on the RMP Safer Communities by Chemical Accident Prevention Proposed Rule. How Did The RMP Rule Come About? Section 112(r)(7) of the Clean Air Act Amendments require EPA to publish regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances. These regulations and guidance are contained in the RMP rule, which requires facilities using extremely hazardous substances to develop programs to prevent and mitigate accidents that could release those chemicals into the environment. EPA published its first such regulation in 1996. Then in January 2017, the RMP Amendments Final Rule issued new requirements for prevention, response, and public disclosure of information – but key provisions were paused, and most never went into effect. Instead, in 2019, the RMP Reconsideration Final Rule rescinded or modified some of the measures in the 2017 rule. How Many Facilities Are Subject to the RMP Rule? Currently, EPA regulates about 12,000 RMP facilities throughout the country such as agricultural supply distributors, water and wastewater treatment facilities, chemical manufacturers and distributors, food and beverage manufacturers, chemical warehouses, oil refineries, and other chemical facilities. Local Facilities Subject to the Risk Management Plan Rule Because Title V operating permits issued by the Allegheny County Health Department (ACHD) incorporate Risk Management Plan regulations, all of those facilities would be subject to the new rule. GASP continues to follow this issue and will keep you posted as the rulemaking process proceeds.

GASP joins the state Department of Environmental Protection (DEP) in reminding Pennsylvanians that they have opportunities all around them to curb pollution, and they can start by looking in their closets and around their homes. Recycling unwanted and/or gently used clothing and items like furniture and other home goods is an effective strategy to curb pollution that would otherwise make its way into local landfills. Which is an issue: DEP estimates that about 10 percent of municipal waste - or 500,000 tons - is made up of textiles, furniture, and other household goods. DEP also wants to get the word out about a mobile application available to residents to help them better understand how to best recycle these household items. Developed by the Pennsylvania Recycling Markets Center, the online exchange platform allows interested citizens, businesses, and public officials to post recycled items and materials for others who may be interested in acquiring them. As the holiday season approaches, the department also reminded residents that secondhand and vintage shopping is an environmentally-conscious way to make an impact. For more information on recycling programs in Pennsylvania, please visit: https://www.dep.pa.gov/Business/Land/Waste/Recycling/pages/default.aspx Editor’s Note: You can read more about how fast fashion impacts air quality here. You can learn more about where to shop at local vintage and second-hand shops here.

It was a busy year for us here at GASP, one spent doing what we do best: Advocating for policy changes to help improve air quality, educating folks (young and old) about the impacts of air pollution, and acting as a legal watchdog to both industrial polluters and the governmental agencies charged with regulating them. And as we head into the waning days of 2023, we wanted to stop and say THANK YOU. Helping to initiate real policy changes at the local and regional levels takes sustained tenacity and grassroots support. Truly, we couldn’t do what we do without your help. This year, GASP continued its dogged pursuit of improved air quality - with a special focus on the issues being faced by our neighbors in the Mon Valley living in the shadow of U.S. Steel’s Clairton Coke Works. We called out the polluter for its role in the Mon Valley’s longstanding hydrogen sulfide issue, demanded improved communications and better transparency from the Allegheny County Health Department, and helped residents navigate and speak out about a high-profile settlement agreement regarding emissions from the Edgar Thomson plant. But our advocacy work extends beyond the Mon Valley. This year, our legal watchdog efforts included reviewing and commenting on myriad air pollution-related policies and permits to ensure that all the applicable rules and safeguards were, in fact, being applied. Just this fall, our attorneys informed a Beaver County landfill opportunity of our intent to sue if issues with its air quality permits weren’t resolved (more to come on that). This year we were also notified that the EPA awarded us funding to expand local citizen air quality monitoring and fill in data gaps (!!!). Despite regulatory air quality monitors and a growing network of citizen-owned low-cost sensors, it’s still difficult for residents to know exactly what pollutants they’re inhaling. GASP is teaming up with six fellow environmental groups to help solve that environmental justice issue locally thanks to a nearly $500,000 EPA grant. The project is expected to enhance ambient air quality monitoring in communities that are underserved, historically marginalized, and overburdened by pollution. We can’t wait to get started. And we’d be remiss if we didn’t tell you a little about our education programming, too. In addition to embarking on the second year of our Fresh Voices for Clean Air youth education initiative, we crafted a primer for municipal officials and staff so they can better understand - and serve you regarding - important air quality issues. Stay tuned, GASP will be hosting workshops throughout 2023. If you’re a municipal official or staff member reading this and you’d like more information, don’t hesitate to email our executive director Patrick Campbell at patrick@gasp-pgh.org). From our gang to yours: Happy New Year. We look forward to working alongside you in 2023. P.S. If you’d like to make a year-end, tax-deductible donation to help us start the new year on strong financial footing, you have until Dec. 31. Checks can be mailed to our office at 1133 S. Braddock Ave #1a, Swissvale, PA 15218. Donations may also be made on our website.

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.

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.

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.