Last week was one of excess for those in and around the Mon Valley, but not for the Thanksgiving-related reasons you might think: sadly, excess air pollution caused residents to grapple with abysmal air quality over the holiday break. In summary, concentrations of fine particulate matter (PM2.5) exceeded national health-based standards at the Allegheny County Health Department (ACHD) air quality monitor in Liberty Borough three days in a row while levels of hydrogen sulfide (AKA H2S, that rotten egg odor you likely know all too well) exceeded the state standard six straight days. For a less-quick, more-detailed recap, we need to go back a full week. Air quality wasn’t great last Monday, and it got worse as the week proceeded. By Tuesday afternoon, both ACHD and the Pennsylvania Department of Environmental Protection (DEP) predicted air quality would continue this downward trend and shared their concerns publicly: ACHD issued a Mon Valley Air Pollution Watch, and DEP declared a Code Orange Air Quality Action Day for PM2.5 – both for Wednesday in the Mon Valley. As a reminder, Mon Valley Air Pollution Watches and Warnings are issued as part of the county’s Mon Valley Air Pollution Episode Rule, which was designed to reduce PM2.5 levels during prolonged periods of poor air quality. Under the new rule, ACHD staff monitor weather forecasts and atmospheric conditions that could lead to an “episode” (i.e., when meteorological conditions are likely to contribute to unacceptable air pollution levels in the Mon Valley for a day or more). A Watch is issued when these conditions are likely, and a Warning is issued when these conditions occur. Early Wednesday, ACHD upgraded its Watch to a Warning, but that was a bit late by our calculations; PM2.5 crossed the “threshold” value necessary for a Warning around 10 p.m. Tuesday. When ACHD issues a Warning – as it did last week and for a span of four days last month – sources of PM2.5 emissions within a defined Mon Valley area subject to the new rule are required to follow approved mitigation plans to reduce their emissions of particulate matter. We have a great explainer with info on the rule and all the facilities subject to it. You can check that out here. Later on Wednesday – while those Warning plans were in place – ACHD extended its Mon Valley Warning into Thanksgiving and DEP declared a second Code Orange Air Quality Action Day for PM2.5 for the same day. ACHD again extended the Warning through Friday, and downgraded it to a Watch through Saturday - but by then the worst of the air quality has passed. In the end, PM2.5 at ACHD’s monitor in Liberty Borough exceeded national health-based standards on Tuesday, Wednesday, and Thursday, but PM2.5 wasn’t the only pollutant of concern during this period of poor air quality: Levels of stinky old H2S exceeded Pennsylvania’s 24-hour average standard six straight days (from Tuesday through Sunday). It’s also worth noting that concentrations of H2S exceeded PA’s 24-hour average standard on Wednesday at ACHD’s air quality monitor in Braddock Borough. 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. This latest bout of poor air quality highlights two issues that we believe should be on ACHD’s to-do list: The department must examine the Mon Valley Air Pollution Episode Rule implementation to determine its effectiveness and ensure it protects public health. The department must do more to stop the onslaught of H2S exceedances in the Mon Valley. ACHD leaders have, in the past, treated H2S as a quality-of-life issue and downplayed its impact on the health and well-being of local residents. After six straight days of stench and H2S concentrations known to have health impacts, residents deserve better. “We know that ACHD issued an enforcement order against U.S. Steel related to H2S violations at its Clairton Coke Works facility this past March, but what have they done since?” GASP Executive Director Patrick Campbell asked. “People who live and work in the Mon Valley and downwind of it need to know the people charged with protecting their health are being as proactive as possible to stem this ongoing issue.” Editor’s Note: We will continue to keep an eye on the data and keep you posted. In the meantime, we graphed recent H2S and PM2.5 concentrations at the Liberty monitor for those who’d like to take a deeper dive into the data:

This Giving Tuesday, we want to be upfront with the reality of air quality advocacy: It remains largely a David vs. Goliath endeavor. On one side, you have the multi-million dollar and sometimes even multi-billion-dollar companies with their slick corporate attorneys and exorbitant public relations budgets. On the other side, you have residents and groups like GASP. That’s not us being all doom and gloom - we know who we are: A watchdog organization that’s always thrived in the underdog role. Despite our small team and modest budget, your support over the years has allowed us to wield outsized influence to help improve regional air quality and hold both polluters and regulators accountable. And we want to keep on doing what we do best. We know there are SO MANY outstanding local nonprofit organizations seeking your support. So we’re serving up six reasons we think you should consider supporting the gang here at GASP: Our work gets action + answers. After years of demanding information and action and thousands of odor complaints, ACHD in March revealed the source of sky-high hydrogen sulfide concentrations at its Liberty air quality monitor that regularly exceeded Pennsylvania’s regulatory standard and impacted residents’ health and quality of life: U.S. Steel’s coking operations in Clairton. In March, the department published a comprehensive air quality study detailing its research and issued a $1.8 million enforcement action against the Mon Valley steelmaker. We help equip residents with the knowledge they need to speak out about air quality issues. We know air quality issues are complex and the public comment process can be confusing. That’s why we take great care to break down complex issues into plain language in our watchdog blogs. This year, hundreds of residents used our online forms to submit comments on local issues like the proposed consent decree calling for extensive improvements to U.S. Steel’s Edgar Thomson facility to broader issues like the Regional Greenhouse Gas Initiative. We launched a new, more user-friendly website. We streamlined our site and added new bells and whistles to allow us to better communicate action alerts, events, and news. We’re hosting air quality “boot camps” for municipal officials so they can better serve YOU. Thanks to a grant from the Pennsylvania DEP, we’ve crafted an educational primer that addresses all things air quality. And we’re taking it on the road to air quality “boot camps” for municipal officials in Allegheny and surrounding counties. The EPA awarded us funding to expand local citizen air quality monitoring and fill in data gaps. 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. You can depend on us. We care 24/7. And we hope we prove that to you every single day. From our daily social media posts and blogs to our weekly newsletter, you can depend on GASP to be among the first to tell you about everything from alerts regarding periods of abysmal air quality to opportunities to speak out on important permits and regulations. If you are able to make a donation, please know that we are so appreciative. As always, those who would like to make a donation through the Give Big Pittsburgh platform can do so here you can also feel free to make a donation on our website. If you have questions, our member services manager Kathy Lawson can give you a hand, just email her at kathy@gasp-pgh.org to set up a time. We can’t say it enough: Thank you, thank you, THANK YOU. Supporters like you have helped GASP to be here for the long haul. With your help, we’re looking forward to making even more strides for clean air in 2023. Yours for Clean Air, The GASP Gang

UPDATE #2 (4:31 p.m. Wednesday, Nov. 22): The state Department of Environmental Protection on Wednesday afternoon declared Thursday, Nov. 23 a Code Orange Air Quality Action Day for particulate matter. UPDATE #1 (2:40 p.m. Wednesday, Nov. 22): The Allegheny County Health Department issued the following message through its Allegheny Alerts system: The Mon Valley Air Pollution Warning will continue through at least the end of tomorrow, November 24. A strong weather inversion with light winds will permit fine particle matter pollution (PM2.5) to build overnight into Thursday morning. The highest PM2.5 concentrations will come between 3 a.m. and 11 a.m., leading to overall average concentrations in the CODE ORANGE range in the Mon Valley. Because of these conditions, the Pennsylvania Department of Environmental Protection has declared tomorrow an Air Quality Action Day. The Air Quality Program will continue to monitor the situation and reassess conditions and provide more information to residents, as it becomes available. Young children, seniors, and those with respiratory problems, such as asthma, emphysema, and bronchitis, are especially vulnerable to the effects of air pollution and should limit outdoor activities during this time. Foul air quality has returned to the Mon Valley this week with residents waking up Wednesday to surging concentrations of particulate matter and hydrogen sulfide, as well as a NowCast AQI of 164 indicating air quality reached a level the EPA classifies as unhealthy and which was, for a time, the very worst in the nation. But the trouble started yesterday when concentrations of fine particulate matter (PM2.5) exceeded federal health-based standards at ACHD’s air quality monitor in Liberty Borough. Monitor data also showed levels of hydrogen sulfide (H2S) exceeded Pennsylvania’s 24-hour average standard. As a reminder: H2S is 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. Unfortunately, these abysmal air quality conditions are expected to persist today and tomorrow. Yesterday the Allegheny County Health Department (ACHD) issued a Mon Valley Air Pollution Watch while the state Department of Environmental Protection (DEP) declared today a Code Orange Air Quality Action Day for particulate matter. By early Wednesday, ACHD upgraded the Watch to a Warning. Here’s the message ACHD sent through its Allegheny Alerts system: An Air Pollution Warning has been issued for the Mon Valley for today, November 23. The 24-hour PM2.5 standard for the Mon Valley has been exceeded at an official monitoring station in the Mon Valley. Young children, seniors, and those with respiratory problems, such as asthma, emphysema, and bronchitis, are especially vulnerable to the effects of air pollution and should limit outdoor activities during this time. Companies most significantly contributing to particulate pollution in the Mon Valley region are required to temporarily reduce particulate emissions. As a reminder, Watches and Warnings are issued as part of the county’s Mon Valley Air Pollution Episode Rule, which was designed to reduce PM2.5 levels during prolonged periods of poor air quality. Under the new rule, ACHD monitors weather forecasts and atmospheric conditions that could lead to an “episode” (i.e., when meteorological conditions are likely to contribute to unacceptable air pollution levels in the Mon Valley). A Watch is issued when these conditions are likely, and a Warning is issued when these conditions occur. When ACHD issues a Warning - as it did this morning and for a span of four days last month – sources of PM2.5 emissions within a defined Mon Valley area subject to the new rule are required to follow approved mitigation plans to reduce their emissions of particulate matter. We have a great explainer with info on the rule and all the facilities subject to it. You can check that out here. "We've heard from residents complaining of itchy eyes and throats and telling us that by early morning they had already needed tor each for their rescue inhalers," GASP Executive Director Patrick Campbell told the Tribune-Review Wednesday. "It's truly a shame how often residents in the Liberty-Clairton area are confronted with unhealthy air quality. People are really suffering today." The GASP team is keeping an eye on the data and will keep you posted.

The now-shuttered Erie Coke Corp. and one of its corporate officers have been indicted by a federal grand jury for violations of the Clean Air Act and conspiracy to violate the Clean Air Act the Justice Department announced Thursday. The eight-count indictment, returned on Tuesday and unsealed today, named Erie Coke Corp., now permanently out of operation, and Anthony Nearhoof, 41, of Pittsburgh, as the defendants. Nearhoff was arrested Wednesdays by special agents, according to legal documents. According to the indictment, Erie Coke Corp. and Nearhoof tampered with measurements on heating systems that emitted contaminants and pollutants into the air including volatile gasses such as benzene, toluene, and xylene from October 2015 through December 2019. The indictment alleged Nearhoof was an operator and “responsible corporate officer” at the plant when hazardous air pollutants were being released and directed other plant supervisors and foremen to vent combustion gasses directly into the air to avoid the plant’s environmental monitoring system. “Nearhoof directed, instructed and pressured employees…to open coke oven flues to vent emissions in a manner that bypasses the Continuous Opacity Monitor,” the indictment reads. “Such directives occurred via personal directives, by radio to workers on the batteries, and sometimes in writing in a log book used by battery foremen to convey information from shift to shift.” The Justice Department said the indictment demonstrates its “ongoing commitment to securing environmental justice” by holding Erie Coke Corporation and its management responsible for violations of laws meant to protect the environment and the community. “It is important to protect our community from environmental health hazards and to ensure equal access to a healthy environment in which to live, learn, and work,” U.S. Attorney Chung said in a statement. Jennifer Lynn, the special agent in charge for the Mid-Central Area Branch, agreed. “Today’s indictment holds Erie Coke Corporation and its management responsible for covering up and lying to federal regulators and the public about their discharges,” she said. “Through thorough investigative efforts by EPA and its state partner, we were able to uncover the fraudulent scheme.” GASP supported the community group Hold Erie Coke Accountable in its work to end Erie Coke’s noxious odors and billowing plumes emanating from the plant perched on Lake Erie’s shore. You can read about that work here.

GASP on Nov. 15 sent a Beaver County landfill operator a notice of intent to sue under the Clean Air Act and Pennsylvania Air Pollution Control Act. The notice is based on the landfill’s continued failure to submit a timely application for a Title V operating permit as required by the Clean Air Act. “We are determined to bring the Brunner Landfill in New Sewickley Township into compliance with the Clean Air Act’s Title V Operating Permit requirement,” GASP Executive Director Patrick Campbell said. “Both the Clean Air Act and Pennsylvania’s Air Pollution Control Act authorize citizen suits to abate continuing violations of the air pollution control laws, including permitting requirements.” Title V operating permits are important because when issued, they must include all emission limits and operating restrictions to which the source is subject. Such permits make it easier to determine whether or not the source is complying with those limits and restrictions. The Brunner Landfill has been in operation for nearly 35 years but first applied for a Title V Operating Permit in 2013, according to state Department of Environmental Protection records. However, during the 25 years between 1988 (when the landfill began operating) and 2013, the landfill did apply for - and was issued - plan approvals for pollution control devices including a flare that destroys landfill gas and a leachate evaporation system that reduces amounts of hazardous solid and liquid wastes. Then in 2015 - before DEP acted on the landfill’s initial application for a Title V Operating Permit - the landfill replaced its then-existing landfill gas flare and leachate evaporation system without getting prior authorization from DEP, something prohibited by Pennsylvania’s Air Pollution Control Act. “The unauthorized replacement of those flare and leachate evaporation systems rendered the landfill’s 2013 application for an operating permit incomplete because the equipment described by the permit application no longer matched the equipment at the facility,” GASP senior attorney John Baillie explained. Accordingly, DEP never acted on the application. While Brunner landfill did finally submit a revised Title V permit application in June 2020, DEP deemed it incomplete and returned it in September 2021, telling facility operators they had failed to provide the required notice to Beaver County and New Sewickley Township officials. Since then, Brunner hasn't resubmitted its application for a Title V Operating Permit. The federal regulations that require most landfills (including Brunner Landfill) to have Title V Operating Permits established a June 21, 2022 deadline for them to do so. If you’re asking yourself, “It’s been nearly 35 years, what difference does it make for the landfill to have an operating permit now after all this time?” two problems come to mind. “First, because the landfill is operating equipment that has not been properly permitted, valid limits and restrictions have not been established for the equipment,” Baillie explained, “It may be impossible to determine for sure whether the equipment is being operated properly until acceptable performance tests are conducted, and such limits and restrictions are set.” Second, it appears that the landfill currently may not be subject to emission reporting requirements. When we checked on Oct. 21, 2022, no information about the landfill’s emissions was available on DEP’s webpage for Air Emissions Reporting. That makes it impossible to know just how much air pollution the landfill is creating. The landfill has 60 days to submit a complete application for a Title V Operating Permit before GASP is permitted to file a complaint in federal or state court. Editor’s Note: You can read the entire letter GASP sent to Brunner here.

The Donora Smog Disaster of 1948 is perhaps the most infamous air pollution event in American history. That weekend of horrific air quality killed 20 people and sickened thousands more, but it also galvanized residents to take environmental action - a movement that culminated in the creation of the Clean Air Act. We hope you’ll join us at 6:30 p.m. Dec. 14 for our online event, Making the Connection: The Lessons Learned (and Unlearned) from the Donora Smog Disaster. The event will feature a panel of local experts including: Mark Pawelec and Brian Charlton, historians from the Donora Smog Museum. Scott Beveridge, a retired, award-winning investigative journalist from the Observer-Reporter newspaper in Washington County whose work uncovered new details about the disaster and its fallout. Myranda Fullerton, a meteorologist from the National Weather Service. During the 90-minute program, attendees will have the opportunity to view rare historical videos, learn from experts how U.S. Steel used a combination of public relations and victim blaming to downplay its role in the killer smog event, and hear heart-wrenching stories of personal loss and environmental damage gleaned from the pages of long-forgotten court documents. The event is free but registration is required and can be accomplished here.

Allegheny County Health Department’s regulation subcommittee is slated to meet at 5:30 p.m. Tuesday, Nov. 15 to discuss, among other things, proposed changes related to the Clean Air Fund. Among the proposed changes is how much of that money can potentially go back into ACHD’s coffers. Right now, county air pollution control regulations allow ACHD to request up to 5 percent of the Clean Air Fund’s year-end balance annually for operating expenses. The Air Quality Program is requesting that be changed to allow the department to request up to 25 percent of the Clean Air Fund balance with a cap of $1,250,000. The meeting will be held in person and online and is open to the public. You can get all the details about how to join here (scroll down). Editor’s Note: Can’t make it? No worries. GASP’s senior staff attorney is a member of the subcommittee meeting and several of our other team members will be in attendance so we will keep you posted on what happens.

A new class action lawsuit against U.S. Steel alleges the company’s negligent practices at its Braddock-based Edgar Thomson facility led to dust blanketing local homes and noxious odors waking residents from sleep and otherwise interfering with their ability to enjoy their property. The Nov. 1 complaint filed on behalf of West Mifflin resident Alissa Finley “and all others similarly situated” accuses the Mon Valley steelmaker of “failing to install and/or maintain adequate technology to control the emission of noxious odors and fugitive dust” and seeks compensatory and punitive damages for what it called “reckless indifference to the rights of others.” According to the suit: “(U.S. Steel) knowingly breached its duty to exercise ordinary care and diligence when it improperly maintained, operated, engineered, constructed, and/or designed the facility and knew, or should have known, that such actions would cause Plaintiff’s property to be invaded by noxious odors and particulates.” The suit seeks to represent those who owned or occupied residential properties within a one-mile radius of the Edgar Thomson facility since 2020. According to the complaint, there are 3,746 households that meet those criteria but the complaint notes the "boundary is subject to modification" as the case progresses. Residents from more than 70 of those households have already been in contact with the firm filing the suit. This, of course, isn’t the first legal action spurred by emissions issues at the Edgar Thomson Works: In September, county and federal air quality regulators announced they had entered into a proposed consent decree with U.S. Steel to settle years of air quality violations at the facility. The proposed decree – signed by the Mon Valley’s most egregious air polluter, the Environmental Protection Agency (EPA), and Allegheny County Health Department (ACHD) – calls for U.S. Steel to pay a $1.5 million civil penalty and make numerous improvements to the facility. The proposed agreement, which was subject to a public comment period, has not yet been finalized. You can read all about that on our watchdog blog here. Editor’s Note: The Nov. 1 complaint is a private action outside of the regulatory framework and is not subject to a public comment period. You can read the entire legal document here.

We know: It’s been a rough month when it comes to air quality. We read your social media posts and SmellPGH reports, which detailed physical symptoms like itchy eyes, scratchy throats, and breathing difficulties. We were right there with you when lamented having to shutter windows and forgo outdoor activity on downright gorgeous fall days because of off-the-charts air pollution concentrations. Now, we want to make sure the Allegheny County Board of Health understands just how much the abysmal air quality this past month has impacted you and your family - your health and your quality of life. We want to make sure the experience - the suffering - of those living and working in the Mon Valley (and those downwind of it) this month wasn’t in vain. That’s why we are asking you to join us next week in letting the Board of Health know just how bad it was this month. GASP signed up to present public comment at the meeting slated for 12:30 p.m. Nov. 2 and we hope you’ll join us in speaking out and demanding better. You - we - deserve better public communications during periods of expected unhealthy air quality and messaging. We deserve tweaks to the Mon Valley Air Pollution Episode Rule to make it more protective of public health and more accountable to the public. And we need the Board of Health to demand better from its health department leaders when it comes to these crucial air quality issues. The upcoming Board of Health meeting will be held in-person at 12:30 p.m. Nov. 2 in the Gold Room of the Allegheny County Courthouse. For those who cannot attend in person, the meeting can be live-streamed on ACHD’s Facebook page (no account needed). But the deadline to speak out is creeping up fast: Those who wish to send written comments to the board can do so using this form. These comments go directly to board members and will be summarized at the meeting. Use this form to register to speak at the meeting. The deadline to submit written comments or sign up to address the board in person is 12:30 p.m. Nov. 1 (24 hours in advance of the meeting). Please note: Individuals who would like to request an accommodation to attend, or otherwise participate in the meeting, need to do so by 12:30 p.m. Friday (at least 72 hours in advance) here. You can view the meeting agenda here. Editor’s Note: Need a refresher about this most recent bout of bad air quality? Here’s what you need to know.

At GASP, sometimes we read commentaries on air quality so bereft of facts, insight, and empathy that we must respond. The Oct. 18 Pittsburgh Post-Gazette editorial addressing the onslaught of hydrogen sulfide exceedances in the Mon Valley this month titled, “Hydrogen sulfide alerts bring good and bad news” is one such commentary. Our criticism starts with the title itself: “[Insert any pollutant here] alerts” can never be “good news.” Ever. Under any circumstances. Basic human decency demands that people being exposed to any “alert” level of air pollution must always be “bad news.” Having to even point that out is deeply troubling. The editorial’s opening line was not an improvement. In it, the editorial board framed the most recent hydrogen sulfide (H2S) problem as one that lasted “several days.” In fact, on all seven days of the week in question (Oct 9 - 16), Allegheny County Health Department (ACHD) air monitor data from Liberty Borough showed concentrations of H2S exceeded the state 24-hour standard (see data graph at the end of this story). Describing an entire week as “several days” is grossly misleading, but failing to mention the five additional exceedances of the standard immediately adjacent to that week (Oct 5, 6, 7, 16, and 17) is just poor journalism. To its credit, the editorial board pointed out the likely culprit – U.S. Steel’s Clairton Coke Works – as well as ACHD’s efforts to reign in H2S emission via a $1.8 million enforcement action. No credit is due the editorial board for its ensuing series of fact-bending, disingenuous statements that made us question the very purpose of the Editorial. The board suggested inversions – not industrial emissions from polluters like U.S. Steel – “caused” the problem. False. Inversions only limit air pollution's ability to disburse. Think of it this way: If someone passes gas in an elevator versus an open field, the human experience for those nearby is worse in the elevator but the elevator didn't “cause” the episode. The “cause” is more correctly a lack of consideration for neighbors and/or the failure to manage internal processes. The board asserted as a fact that the H2S issues “were not caused by increases in emissions from the U.S. Steel facility” but it could not possibly make that statement based on independently verified facts just days after the exceedances. In fairness, GASP cannot fully assess blame for the precise, technical cause of the exceedances either, but it is worth noting that on Oct. 5, H2S levels at the Liberty monitor exceeded 0.100 parts per million, twice. Before then, concentrations of H2S that high had only been measured nine times in the past 20 years. We think that maybe – just maybe – something out of the ordinary was going on. The board suggested, “the impact of H2S on human health is small” and that “[c]ompared to EPA-regulated pollutants like particulate matter and sulfur dioxide . . . H2S is benign.” It was here, along with later incorrect or misleading assertions about these more “dangerous” pollutants meeting federal standards, that the editorial took its largest step away from respectability. We cannot imagine the level of arrogance or detachment from reality necessary to think, “Not long ago, stinky hydrogen sulfide would have been the least of residents’ worries.” Did the editorial board think one pollutant disrupting and interfering with residents’ lives should be celebrated as proof that other pollutants are ruining fewer lives? Did the board mean that residents who had suffered through this most recent bout of poor air quality should be grateful it wasn’t worse? That is how it felt, meaning it felt morally reprehensible. Whether or not some pollutants are less of a concern today, the editorial displayed an unconscionable disregard for the experience of living, breathing people whose health and wellbeing have been interrupted all too often by poor air quality – in the past and in the past few weeks. Newspapers have a duty to take responsibility for the accuracy of their work and verify information before publication. Displaying some level of humanity is also a nice touch. The Editorial Board should know better. Post-Gazette readers and local residents suffering from the effects of air pollution certainly deserve better. Editor's Note: We graphed recent H2S concentrations for those who would like to take a deeper dive into the data.