In February 2017, the Pennsylvania Department of Environmental Protection (DEP) published revisions to “GP-5,” its existing general operating permit and plan approval for natural gas compressor stations, processing plants, and transmissions stations, as well as a proposed new general operating permit and plan approval “GP-5A” for unconventional natural gas well sites and pigging operations. General permits and plan approvals are available to categories of similar sources that are amenable to regulation using standardized specifications and conditions; DEP is able to streamline the approval process for such sources by using general permits. The revisions to GP-5 and proposed new GP-5A were the cornerstones of Gov. Tom Wolf’s plan to reduce the natural gas industry’s emissions of greenhouse gases and other types of air pollution. According to DEP, it received over 10,000 comments from the public (including one from GASP) regarding the 2017 revisions to GP-5 and proposed GP-5A. DEP has revised GP-5 and GP-5A further, purportedly in response to those comments, and published new versions of GP-5 and GP-5A for public comment on March 31, 2018 (comments will be accepted through May 15, 2018). The 2018 versions of GP-5 and GP-5A differ from the 2017 versions in several respects, not all of which should be welcomed by those concerned with minimizing pollution from the natural gas industry. First, the 2018 versions of GP-5 and GP-5A expressly rely on Subpart OOOOa of the federal New Source Performance Standards to a much greater extent than did the 2017 versions. A full comparison of Subpart OOOOa, the 2018 versions of GP-5 and GP-5A, and the 2017 versions of GP-5 and GP-5A are beyond the scope of this blog post. Although the requirements imposed by Subpart OOOOa generally received positive reviews from environmentalists when they were introduced in 2016, Subpart OOOOa can be revised by the United States Environmental Protection Agency (EPA). In fact it already was, in June 2017, and thus limitations applicable to the natural gas industry in Pennsylvania will be subject to the agenda of whomever is control of EPA to a greater extent under the 2018 versions than they would have been under the 2017 versions. Second, with respect to GP-5, the 2018 version departs from the 2017 version in several other respects: The 2018 version eliminates permit requirements relating to the control of fugitive particulate matter (meaning, dust) from natural gas compressor stations and processing plant sites. The 2018 version reduces the required destructive efficiency of flares used to control emissions from compressor stations and processing plants meeting certain thresholds (namely, the uncontrolled potential to emit 200 tons per year of methane, 2.7 tons per year of volatile organic compounds, or 0.5 tons per year of any single hazardous air pollutant) from 98% to 95%. The 2018 version reduces the allowable rate of emissions of some types of air pollution from some types of stationary spark internal combustion engines at compressor stations and processing plants; the 2018 version also increases the allowable emission rates of air pollution from some types of such engines. The 2018 version eliminates a requirement that pumps and controllers at compressor stations and processing plants be run on electricity when a connection to the electrical grid is available. The 2018 version eliminates the requirement that natural gas-fired combustion units at compressor stations and processing plants be equipped with and operate fuel flow meters. Third, with respect to GP-5A, the 2018 version also differs from the 2017 version in several ways: The 2018 version eliminates regulations relating to fugitive particulate matter from well sites and pigging operations, well drilling and hydraulic fracturing operations, well completions, and natural gas-fired combustion units at natural gas well sites and pigging operations. However, Subpart OOOOa does include operating requirements that are applicable to emissions from well drilling, hydraulic fracturing, and well completions, so such emissions will not go unregulated. As with GP-5, the 2018 version of GP-5A reduces the required destructive efficiency of flares used to control emissions from natural gas well sites and pigging operations meeting certain thresholds (namely, the uncontrolled potential to emit 200 tons per year of methane, 2.7 tons per year of volatile organic compounds, or 0.5 tons per year of any single hazardous air pollutant) from 98% to 95%. Also as with GP-5, the 2018 version of GP-5A reduces the allowable rate of emissions of some pollutants from some types of stationary spark internal combustion engines at natural gas well sites and pigging operations; the 2018 version also increases the allowable emission rates of some pollutants from some types of such engines. The 2018 versions of GP-5 and GP-5A are available on DEP’s web site, at http://www.dep.pa.gov/Business/Air/BAQ/Permits/Pages/GeneralPermits.aspx. Should you wish to comment on the 2018 versions, send your comments to DEP by May 15, 2018 using its eComment system at www.ahs.dep.pa.gov/eComment, or by e-mail to ecomment@pa.gov. Written comments may be mailed to the Policy Office, Department of Environmental Protection, Rachel Carson State Office Building, P.O. Box 2063, Harrisburg, PA 17105-2063. No matter how you submit your comments, remember to include your name and address on them. –John Baillie, Staff Attorney #volatileorganiccompounds #airpollution #compressorstations #naturalgas #GP5A #JohnBaillie #particulatematter #DEP

THANK YOU to everyone who attended our event Making the Connection: What the Donora Smog Disaster Can Teach Us 74 Years Later. You can check out the event recording here: We also want to extend another HUGE thank you to our panelists. You can learn more about the Donora Smog Museum on its website here. On his blog, Travel with a Beveridge, you can read retired journalist Scott Beveridge's work related to the Donora Smog Disaster. And be sure to follow our friends at the National Weather Service on Twitter and Facebook.

GASP’s resident smoke reader - longtime project manager Sue Seppi - was back at it again last week, with stops in Clairton and Braddock to observe emissions emanating from U.S. Steel’s Clairton Coke Works and Edgar Thompson facilities. For those who might not be familiar: smoke readers are volunteers who are trained and certified to recognize and understand: visible emissions from smokestacks what opacity violations look like and how to file reports with the Allegheny County Health Department During her observations, Sue noted concerning brownish plumes and a rotten-egg odor in Clairton and reported it to the Allegheny County Health Department, our local air quality regulator. She also reported high-opacity smoke from the Edgar Thomson facility. Here’s the report she sent in: Seeing frequent similar brownish plumes or sometimes parts of plumes (due to wind keeping plume flow flattish and sometimes behind buildings at Clairton Coke) as seen on previous visits in the same general area. On Dec. 9, 2022, opacities of plume or partial plume were frequently 20% or higher during a 20-minute period starting at 12:28 pm. I can't see the source. Are these plumes or plume permitted? On this visit, the plume/s in this area were not as long-lasting as previously. At Edgar Thomson, I observed some heavier opacity plumes on two different dates (see photos) from the same general area-not sure of the source. Are these plumes permitted? At Clairton, there was a persistent rotten egg odor (Maple Ave.) not at Edgar Thomson (from the opposite side of Allegheny River from ET). Thank you for the opportunity to send comments that may be of assistance to you and healthy air quality. Editor’s Note: Stay tuned, we’ll keep you posted on ACHD’s response. Last month, the department said it was investigating brown plumes Sue reported. You can learn more about that report here.

The U.S. Environmental Protection Agency (EPA) is now accepting applications from state, local, and tribal air agencies for grant funding to assist them in conducting air quality monitoring projects of hazardous air pollutants (also called air toxics). Given that Allegheny County residents in several communities live and work uncomfortably close to known sources of air toxics, GASP is calling on the Allegheny County Health Department (ACHD) to pursue funding through this program. At present, the only federal requirements for monitoring ambient air quality cover the six “criteria” pollutants: particulate matter, lead, sulfur oxides, nitrogen oxides, carbon monoxide, and ground-level ozone. Air toxics are controlled and monitored at their source through regulation of industries, vehicles, etc. The EPA tracks those emissions and estimates ambient air concentrations but even the EPA admits the system is not perfect: “Emissions data are one way we can attribute HAP exposures to specific sources. On the other hand, ambient monitoring data allow us to continually evaluate and improve our models and inventories, to deal credibly with the difficult issue of background HAP concentrations, and to measure progress more directly.” Simply monitoring for potentially dozens of different pollutants randomly could be a waste of resources. To address that issue, the new EPA grant program encourages a targeted approach. The EPA press release announcing the grant program states that the agency is awarding up to $5 million from this competitive program to fund projects that fall into one of four categories: Characterizing the impacts of air toxics in a community (community-scale monitoring); Assessing the impacts of air toxics emissions from specific sources (near-source monitoring); Evaluating new and emerging testing methods for air toxics; and Analyzing existing air toxics data and developing or enhancing analytical, modeling, and/or implementation tools. Agencies applying for the air toxics monitoring grants may partner with or provide “subgrants” to other organizations for their monitoring projects. The EPA expects to award as many as 20 projects and no grant will exceed $750,000. Air toxics are linked to cancer or other serious health effects. Under the Clean Air Act, EPA regulates 187 listed air toxic pollutants. While grant applications may address any air toxic pollutant, air toxics of particular interest to EPA in this competition include ethylene oxide, chloroprene, benzene, 1,3-butadiene, and metals such as hexavalent chromium, nickel, and arsenic. GASP believes this grant opportunity could fund monitoring of two particular air toxics of concern locally: benzene and manganese. While there is no EPA requirement to monitor benzene near coke facilities, ACHD does so at its Liberty Monitor site, which is about a mile north-northeast of—and typically downwind of—Clairton Coke Works. That air quality monitor data show concentrations of benzene well below Occupational Safety and Health Administration (OSHA) workplace safety levels, but still above acceptable risk levels for ambient air. The average benzene concentration at the Liberty Monitor was very close to 1 part per billion (ppb) over the past year. The EPA has calculated this level to potentially cause one in 100,000 excess cases of cancer, but the World Health Organization states that as a carcinogen, “no safe level of exposure (to benzene) can be recommended.” These are important reasons why ACHD should want to seek funding for more robust benzene monitoring through the EPA grant program. GASP Executive Director Rachel Filippini said that a framework for such monitoring already exists: The state Department of Environmental Protection (DEP) last year began monitoring benzene near the now-shuttered Erie Coke Corp. The DEP’s approach to monitoring followed an existing and required EPA protocol for monitoring benzene near petroleum refineries. Despite the closure of that coke plant, DEP will continue monitoring efforts there through this year. Preliminary data already show an improvement in air quality since the plant discontinued operations at its facility in Erie. “Hopefully, DEP’s benzene air monitoring program will work as a template for similar data collection in Allegheny County,” she said. “Since a framework is already in place, it might not be that heavy of a lift for ACHD officials to put together a proposal worthy of these EPA grant dollars.” In addition to benzene monitoring, Filippini said there might also be an opportunity for more comprehensive monitoring of manganese, which can be a neurotoxin when inhaled – one that can potentially cause cognitive impairment, mood disturbances, and impaired memory, balance, and coordination. ACHD already monitors for manganese at McConway & Torley (M&T) in Lawrenceville. Since U.S. Steel’s Edgar Thomson Works emits 32 times more manganese than M&T, it would make sense for the Allegheny County Health Department to monitor around the E.T. facility and this EPA grant could potentially help it do just that. “These are two concrete examples of how health department officials could take advantage of this tremendous opportunity to more robustly monitor air pollution locally,” Filippini said. “The pollutants we are talking about are a known carcinogen and neurotoxin. Having a better handle on the sources and processes that are creating these pollutants and then, in turn, working to reduce them is the kind of work the Air Quality Program needs be doing.” She continued: “We all know that poor air quality has long given a black eye to Allegheny County. We hope ACHD will take seriously this grant opportunity, which could potentially pay for hundreds of thousands of dollars in air toxics monitoring.” #USSteel #airtoxics #AlleghenyCountyHealthDepartment #EdgarThomsonPlant #ACHD #ClairtonCokeWorks #airquality

In Southwestern Pennsylvania, the Department of Environmental Protection (DEP) and Allegheny County Health Department (ACHD) each operate a network of air quality monitoring stations. Federal regulations provide a number of technical requirements covering the air quality monitors themselves and require that the monitoring networks meet three basic objectives: 1. provide air pollution data to the general public in a timely manner; 2. support compliance with ambient air quality standards; and 3. support air pollution research studies. GASP believes that monitoring air quality is one of these agencies’ most important tasks because it informs and protects the public. The box on the right side of our homepage, showing current air quality conditions for Pittsburgh, is informed by data from ACHD’s and DEP’s monitoring efforts. To further the goal of public education in this area, GASP has recently added a feature to our permit clearinghouse map: showing all of the air quality monitoring stations in Southwestern Pennsylvania. It’s not by chance that there is a great deal of air quality monitoring sites near concentrations of industrial activity. As noted above, compliance is also an important part of DEP’s and ACHD’s monitoring activities. The Clean Air Act requires each state and local authority to submit an annual report to the EPA describing how it monitors ambient air quality. Although both agencies appear to operate the minimum number of air quality monitoring sites required, GASP’s comments on the ACHD and DEP plans noted several areas where we believe the agencies should be doing more to protect public health: 1. Monitoring near oil and gas operations The task of monitoring, researching, and analyzing air quality around oil and gas operations should be one of DEP’s most fundamental roles as the industry expands in Pennsylvania. For years, citizens have raised air quality concerns and the DEP has admitted that it needs additional monitoring data to properly characterize the risks associated with emissions from these sites. Yet, DEP has failed to implement additional air quality monitoring and must now do so as soon as possible. 2. Monitoring fine particulates (PM2.5) Part of DEP’s oil and gas monitoring plan that it has yet to implement includes monitoring for fine particulate matter near oil and gas operations. Although PM2.5 is only one of several emissions from these sites, this data would help them characterize a host of risks associated with the facilities themselves. In Allegheny County, monitoring for fine particulate matter is essential because the County struggles to meet national ambient air quality standards for this pollutant. Of special concern are emissions from diesel engines and how those contaminants increase in the downtown Pittsburgh area during the morning and evening rush hours. In the coming months, ACHD will be issuing new guidelines aimed at lowering particulate matter concentrations for the entire region. Expansion of monitoring efforts will be critical to ensure that the entire county comes into compliance with the national standard. 3. Sulfur Dioxide Largely due to our region’s continued reliance on coal for power plants and industrial processes, several areas in Southwestern Pennsylvania have elevated levels of sulfur dioxide. Specifically, the Liberty-Clairton area in Allegheny County, a portion of Beaver County along the Ohio River, and all of Indiana County suffer from this issue. Sulfur dioxide causes wheezing, coughing, and shortness of breath. Although the law allows the use of mathematical models to show how sources will comply with emissions limitations, GASP has urged ACHD and DEP to increase the use of air quality monitors to ensure that sulfur dioxide levels in towns and neighborhoods near these sources are within safe levels. –Ned Mulcahy, Staff Attorney #PM25 #airpollution #sulfurdioxide #airmonitoring #NedMulcahy #AlleghenyCountyHealthDepartment #DEP #ACHD #airquality

The Group Against Smog and Pollution (GASP) is teaming up with The CREATE Lab at Carnegie Mellon University for an event—and we need your help! How? We are looking for folks to serve as volunteers to help label smoke emissions from a collection of air pollution monitoring videos. “Our goal is to train an artificial Intelligence system to detect industrial smoke pollution automatically. To do this, we need a vast amount of data, which will require a considerable human effort,” CREATE Lab officials explained. “As we gather more labeled videos, the AI system will begin to detect local smoke emissions, and our team will design visualization for industrial pollution events. We would greatly appreciate your participation in this community-powered AI research!” It’s free to attend. Did we mention refreshments will be served? Interested? Here’s what you need to know if you want to go: When: Choose a session. Either 10 a.m. to 12 p.m. OR 6 p.m. to 8 p.m. on Wednesday, Oct. 16. Where: GASP headquarters located at 1133 S. Braddock Ave. in Edgewood. FYI: We are on the 61B bus route. What to bring:  Attendees should bring their own devices—laptops or mobile devices—since there will be a very limited number available from CMU. The program being used is compatible with Android version 7 or above. For iPad and iPhone, the system is compatible with iOS version 11 or above. For laptops, the tool works on browsers such as Chrome, Firefox, and Safari. How to RSVP: Because space is limited, we ask attendees to RSVP by emailing GASP Executive Director Rachel Filippini at rachel@gasp-pgh.org. #airpollution #RachelFilippini #CREATELab #smokereading #emissions #CarnegieMellonUniversity

The Pennsylvania Department of Environmental Protection (DEP) has opened a follow-up investigation near Erie Coke because of the results of the department’s new passive air quality monitoring sampling. DEP, which received the first three sets of passive air sampling results, found that monitors had indicated that benzene concentrations exceeded a specific action level set forth in the sampling plan. This plan calls for further investigation when the 1.3 µg/m3 action level is exceeded for three sampling events in a rolling 90-day period. “These levels do not indicate an immediate risk for the community; however, they do warrant additional investigation. In each of the first three sets of results, concentrations in excess of the allotted action level were observed in at least one sampling location,” DEP officials said in a press release Wednesday. “There are many potential causes of a sample result above DEP’s action value,” said DEP Northwest Regional Office Director Jim Miller. “Exceeding the action value does not necessarily represent a violation for an applicable requirement or permit condition by Erie Coke, and other sources may be contributing to values recorded. This investigation will aid in determining what specific activities in the area of the Erie Coke plant, on or about the sampling period, could have caused the increased concentration level.” Additional short-term sampling, site inspections, and reviews of facility records will be part of DEP’s investigation. The public will see an enhanced presence of DEP staff in the East Erie community as a result of the investigation. DEP developed the sampling plan in response to concerns raised by the members of a community stakeholder group formed by the DEP, as well as several recent actions requiring Erie Coke to address numerous, ongoing violations of the Pennsylvania Air Pollution Control Act, many of which Erie Coke has appealed and not complied with. The 13 passive air quality monitoring devices, which were deployed July 17 as part of a year-long sampling plan, have been monitoring for benzene, toluene, ethylbenzene, and xylene. The sampling is conducted 24 hours a day, seven days a week. Every two weeks, the tubes are collected, and new tubes are placed within the sampler. View the sampling results on DEP’s website https://www.dep.pa.gov/About/Regional/NorthwestRegion/Community-Information/Pages/Erie-Coke-Benzene.aspx. The site will be updated as new results become available. “The East Erie community, which has been waiting patiently for these results, can now view for themselves the same data we are seeing,” Miller said. “I can’t stress enough though, that this is a long-term sampling plan. We still need much more data to be able to determine the significance of these findings.” Group Against Smog and Pollution (GASP) Executive Director Rachel Filippini lauded the move by DEP. “We are glad to see PA DEP conducting this air monitoring sampling, getting the results out to the community in a timely way, and continuing to conduct further investigations when the action level is exceeded on multiple occasions,” she said. “These are the types of actions we expect from a regulatory agency charged with protecting public health.” On July 1, DEP announced that it denied Erie Coke’s application to renew its Title V operating permit and has filed a complaint for injunctive relief in Erie County Court seeking to shut down the coke production facility following years of numerous repetitive environmental violations. The case is currently before the Environmental Hearing Board. Editor’s Note: GASP is currently reviewing the data. Please check back—this blog will be updated with more information as it becomes available. Until then, here’s some associated media coverage: DEP Investigating Erie Coke Air-Quality Results, GoErie.com PA DEP Opens Investigation Near Erie Coke Due to Air Monitoring Results, YourErie.com Pennsylvania DEP Opens Investigation into Erie Coke Due to Air Monitoring Results, Erie News Now Erie Coke Pleased with Initial Air Quality Monitor Results, Erie News Now #ErieCoke #benzene #airpollution #airmonitoring #DEP #airquality

Along with following up on the long-delayed permitting of the McConway and Torley steel foundry in Lawrenceville, GASP has also been tracking manganese levels recorded at the facility’s fenceline and reported on in the Lawrenceville Toxics Metals Study (viewable here under “Other Air Quality Studies”). Our most recent Making the Connection event, on October 25, 2018, explored manganese exposure and children’s IQ and featured regional experts and their latest research. Their presentations from that evening are posted below. But first some background: Manganese is a naturally-occurring metal found in many types of rocks and soil. Certain foods also contain manganese. And while some ingested manganese is necessary for good health, inhaled manganese is a different story. Manganese becomes airborne from industries using or manufacturing products containing manganese (such as the McConway and Torley foundry), mining activities, and vehicle exhaust. The most common health problems in people exposed to manganese involve the nervous system. Health effects include behavioral changes and other nervous system effects, such as slow and clumsy movements. This group of symptoms is called “manganism.” Other effects such as slowed hand movements have been observed in people exposed to lower concentrations. Manganese can also cross the blood-brain barrier and the placenta during pregnancy, allowing it to reach a developing fetus. Most manganese studies have focused on occupational exposure, so we were quite interested when we learned Dr. Erin Haynes, a Professor of Environmental Health at the University of Cincinnati, was examining the impact of airborne manganese on child neurodevelopment. Dr. Haynes has been conducting research in partnership with communities concerned about their potential exposure to manganese for over a decade. See Dr. Haynes’s presentation: We were also joined by Nancy Beluk. Nancy has been working in the field of MRI for 34 years and is currently focused on MRI research, working at the University of Pittsburgh and the UPMC Children’s Hospital of Pittsburgh as a Research Coordinator in the Pediatric Imaging Research Center. She manages several studies that hope to derive a better understanding between brain dysplasia in children and the potentially adverse neurodevelopmental outcomes that may occur as a result. See Ms. Beluk’s presentation: Manganese is emitted by some industries located in Allegheny County. According to the Pennsylvania Department of Environmental Protection eFACTS, the top emitters of manganese in Allegheny County in 2016 were: U.S. Steel/Edgar Thomson Works in Braddock ATI Flat Rolled Products in Brackenridge Universal Stainless and Alloy Products in Bridgeville NRG Midwest LP in Cheswick McConway and Torley in Lawrenceville To learn more about these facilities, the status of their air quality permits, and GASP’s work to watchdog this issue, please watch GASP Staff Attorney Ned Mulcahy’s presentation: Finally, you can view the informative Question and Answer Session: Please contact us if you’d like more information or to get involved in this issue, or check back to or web site regularly as we’ll be reporting on this and other air quality issues. #Lawrenceville #airpollution #makingtheconnection #McConwayandTorley #airquality #manganese

Dec. 3, 2018 FOR IMMEDIATE RELEASE Geoff Bland, Clean Water Action gbland@cleanwater.org, (412) 765-3053 Zachery Barber, PennEnvironment zach@pennenvironment.org, (412) 973-5023 Residents Urge U.S. Steel to Focus on Cleanup PITTSBURGH, PA – Residents in the Mon Valley and Pittsburgh urged U.S. Steel to stop appealing fines for air pollution violations and focus on fixing the long violating Clairton Coke Works. The Allegheny County Health Department held a hearing today on U.S. Steel’s appeal of ACHD’s $1,000,000 fine for hundreds of recent violations at the Clairton Coke Works. “Residents in the Mon Valley have long suffered from years of poor air quality caused by U.S. Steel’s violations. It’s time for U.S. Steel to invest in our health and jobs in the Mon Valley instead investing in their high-priced lawyers,” said Clairton resident Miriam Maletta. “I’m glad to see that our Health Department is taking action against U.S. Steel for these violations, but when are we going to see U.S. Steel focus on cleaning up their plants? Pittsburgh residents should not have poor air quality because of one company thinking they are above the law,” said Clairton resident Melanie Meade. Air quality scientists at Carnegie Mellon University have conducted detailed studies of air quality in Allegheny County, finding that U.S. Steel’s Mon Valley plants are significantly impacting air quality in over half the county, including in Pittsburgh’s East End. The Environmental Protection Agency (EPA) ranks areas downwind of the Clairton Coke Works in the top 2% nationally for cancer risk from toxic air pollution. Geoff Bland, a community organizer with Clean Water Action stated, “U.S. Steel has been given many years to fix their plant, and still they put out illegal levels of pollution that can make people sick. If U.S. Steel wants to be a good neighbor in Allegheny County, they need to show us they can run this plant in compliance with the law.” “U.S. Steel has treated Pittsburgh’s skies as its dumping ground for decades, filling our lungs with chemicals that can cause cancer and asthma. It’s past time for the company to face serious consequences for their long history of disregard for the health of the city that built them,” said Zachary Barber, the Clean Air Advocate with PennEnvironment Research and Policy Center. In June 2018, ACHD issued an enforcement order against U.S. Steel for multiple and repeated violations of the Clean Air Act, including increasing emissions violations and active attempts of U.S. Steel employees to disrupt official inspection. The order came with $1 million in fines, orders for more rigorous monitoring and a 60-day deadline to improve compliance or face a temporary freeze on operations of the dirtiest parts of the plant. “U.S. Steel’s illegal pollution poses a real risk to the thousands of people who live within 3 miles of the plant and the many more who live in the path of the company’s toxic plume,” said Kelly Yagatich, Outreach Coordinator for the Clean Air Council. This is not the only time the coke works has been cited for breaking the law. A separate enforcement action in October 2018 brought $620,000 in fines for further increases in the number of violations. ACHD also cited the facility for an average of more than three violations per day for a period of four years starting in 2011. “U.S. Steel has been given years to fix the problem, but chose to continue breaking the law,” said Rachel Filippini, Executive Director of the Group Against Smog and Pollution. As one of the largest regional air polluters, the Clairton Coke Works has long been the subject of public outcry. The facility ranked #3 on PennEnvironment’s Toxic Ten ranking of the dirtiest polluters in the county and was the subject of lawsuits by PennFuture and others. “A $1 million dollar fine might sound like a lot, but it really represents only 8 one-thousandths of a percent US Steel’s $12.2 billion in revenue last year, said Matt Mehalik of the Breathe Project. “This would be like fining the average Pittsburgh family $6.09. The fact that U.S. Steel is appealing this enforcement action instead of fixing the problem is disappointing.” ### #enforcementorder #airpollution #USSteel #MonValley #AlleghenyCountyHealthDepartment #ACHD #ClairtonCokeWorks #Clairton #airquality

Title V of the Clean Air Act requires that each major source of air pollution (as well as certain minor sources) have an operating permit that includes all of the air pollution law requirements that apply to the source. The Allegheny County Health Department (ACHD) is responsible for issuing such air quality permits to Title V sources in Allegheny County. A Title V Operating Permit is good for a period of up to five years, but an air pollution source that submits a timely and complete permit application can continue to operate without a permit, or with an expired permit, until the issuing agency acts on the application. The Clean Air Act requires an issuing agency to take final action on an application for a Title V Operating Permit within 18 months of the application’s submittal. We have blogged several times about the Allegheny County Health Department’s backlog of Title V Operating Permits. There are currently 32 Title V sources in Allegheny County, 26 of which are major sources of air pollution. Two of those major sources—Allegheny Ludlum Inc.’s Brackenridge Works and Eastman Chemicals & Resins in Jefferson Hills–have never been issued a Title V Operating Permit. One of the non-major Title V sources of air pollution, Harsco, Inc. (which processes slag at Allegheny Ludlum’s Brackenridge Works), also has never been issued a Title V Operating Permit. An additional eight of Allegheny County’s major sources are operating on permits that have been expired for more than the 18 months allowed by the Clean Air Act. As we’ve written, the U.S. Environmental Protection Agency (EPA) recently reviewed ACHD’s Title V permitting program and directed ACHD to develop a plan to address its backlog of Title V permit applications. ACHD has published its plan. In a nutshell, to eliminate the backlog, ACHD has committed to adding necessary staff and publishing draft Title V Operating Permits for these sources before the end of 2018: Ashland, Inc. Buckeye Pipelines Coraopolis Terminal; Sun Oil; Pittsburgh Terminals/Gulf Oil; Alcosan; and USA Waste/Chambers Development Monroeville Landfill ACHD has committed to issuing Title V Operating Permits for these sources in 2019: NRG Energy–Brunot Island; Harsco, Inc.; U.S. Steel Clairton Works; Bellefield Boiler; and University of Pittsburgh In 2020, ACHD plans to finally issue Title V Operating Permits for Allegheny Ludlum’s Brackenridge Works and Eastman Chemical & Resins, the two major sources that have never had Title V Operating Permits. We will keep our fingers crossed that ACHD sticks to the plan it has outlined to EPA. Of course, GASP will review and comment on the Title V Operating Permits that ACHD does issue as they are published. –John Baillie, Staff Attorney #AlleghenyLudlumsBrackenridgeWorks #airpollution #TitleV #JohnBaillie #Ashland #Harsco #CleanAirAct #AlleghenyCountyHealthDepartment #ACHD #airquality