The Allegheny County Health Department’s notice last week of air quality permits open for comment and issued in final form listed a final operating permit for Pressure Chemical Co., “to include Subpart VVVVVV language.” We’ll guess few of you are familiar with “Subpart VVVVVV,” how it might affect Pressure Chemical, or why it matters. But at GASP, those six V’s marked a small victory and the end to an issue that began almost two years ago. In explaining why GASP was happy to see the facility now officially subject to Subpart VVVVVV, we figured we’d also explain a portion of the unglamorous but important work we do. About Those Air Quality Permits… As supporters might know, GASP’s watchdog efforts include examining drafts of air quality permits published by the Allegheny County Health Department (ACHD) and Pennsylvania Department of Environmental Protection (DEP). By law, agencies like ACHD and DEP must give the public a chance to review certain actions before they become “final” and issuing permits falls into that category. Examination of these documents involves GASP’s staff attorneys verifying that all applicable legal requirements are included, that limits and requirements are being applied to the facility correctly, that the math for any numerical limits adds up, and several other related details. It can be a tedious process. Both the specific pollutants emitted and the types of activities that occur at a facility need to be analyzed. Laws and regulations at the state, local, and federal levels might apply. Taken together, that means GASP staff needs to understand – with a reasonably high level of detail – all the processes at the site that are sources of air pollution as well as all laws and regulations applicable to those sources and pollutants. For those interested, notices of DEP permits are published weekly in the Pa Bulletin and ACHD permit notices are published here intermittently, but normally every four to six weeks. Why GASP Took Issue with Pressure Chemical’s Draft Air Quality Permit In February 2019, we began our examination of a draft permit for the Pressure Chemical Co. facility in Pittsburgh’s Lower Lawrenceville neighborhood. The facility is a manufacturer of specialty chemicals for various clients and does not produce a set list of products. “That variability caught our eye, as did the fact that the permit authorized the facility to store, utilize, and emit several different hazardous air pollutants,” GASP staff attorney Ned Mulcahy said. While reviewing the draft permit GASP determined that it failed to include requirements for “Chemical Manufacturing Area Sources” (those “Subpart VVVVVV” requirements we mentioned earlier). The details of that regulation are – unsurprisingly – tedious, but essentially, they amount to on-site best-practices, emissions controls, and record-keeping requirements for smaller chemical manufacturers. Because of the changing nature of products that Pressure Chemical manufactures, it is not clear if Subpart VVVVVV will tangibly reduce emissions but at the very least, qualifying activities on-site would be subject to additional record-keeping, reporting, and process management. GASP jointly submitted comments with Lawrenceville Clean Air Now (LCAN) in March 2019 noting the VVVVVV deficiency along with a few other concerns. Six months later ACHD issued a final permit, having stated in its final review memorandum discussing the permit that the facility would be subject to Subpart VVVVVV requirements. It was a small but significant victory…for about three minutes. Due to – what GASP would discover later – was a clerical error, the actual, official operating permit issued to Pressure Chemical Co. did not include the applicable Subpart VVVVVV requirements. ACHD corrected the error and issued a revised permit. Pressure Chemical appealed, not over the Subpart VVVVVV applicability but specifically how compliance with it was required in the revised permit. Finally, in September 2020, the appeal was settled and ACHD issued the final permit. The reason for the delay between finalizing the permit and publishing notice of it is not clear. “Having reviewed the final, final version of the operating permit, I’m happy,” Mulcahy said. “Not all of our original comments affected the permit but we helped ensure additional requirements in applicable regulations will now apply to the facility. That is hardly headline news but without our oversight, I’m not sure anyone would have noticed. That alone makes the tedium worth it.” #NedMulcahy #PressureChemicalCompany #emissions #AlleghenyCountyHealthDepartment #airqualitypermits #LawrencevilleCleanAirNow #airquality

Allegheny County Health Department (ACHD) announced in a press release Tuesday that, for the first time in its history, all air quality monitors in Allegheny County have met federal air quality standards. This means air quality in the county now meets federal, health-based standards for carbon monoxide, nitrogen oxide, ozone, and particulate matter (PM2.5, PM10). “This achievement comes after years of hard work by the Health Department, federal and state agencies, and local industry to clean up the air in Allegheny County,” Health Department Director Dr. Debra Bogen said in the release. “But we have more work to do, and the Health Department is committed to ensuring everyone in Allegheny County has clean air to breathe.” GASP Executive Director Rachel Filippini agreed the fight to improve our air quality is far from over. “The 2020 data are promising but we still have way too many days when foul odors and pollution from industrial sources make the air unhealthy to breathe. And our most vulnerable – children, the elderly, and those with heart and lung disease – suffer the most,” she said. “There are still a number of large sources in the County that lack necessary air quality permits and other sources that continue to flout air quality laws.” Based on preliminary data from the department’s monitors, Allegheny County is attaining both the annual and 24-hour standards for PM2.5 for the first time since the Environmental Protection Agency (EPA) set the National Ambient Air Quality Standards (NAAQS) for fine particulate matter in 1999. This represents a significant step in the county’s efforts to improve air quality for all residents. The data are being certified for submission to the EPA for approval. ACHD operates nine air quality monitors that record PM2.5 readings – in Liberty, Avalon, Pittsburgh’s Manchester and Lawrenceville neighborhoods, South Fayette, Harrison, Clairton, North Braddock, and along the Parkway East. Air quality recorded at the Liberty monitor, located near U.S. Steel’s Clairton Coke Works, is the only monitor that has kept Allegheny County from attaining the EPA standard in recent years. The EPA annual standard for PM2.5 is 12 micrograms per cubic meters (µg/m³), averaged over three years. The 24-hour standard is 35 µg/m³, which is also averaged over three years. The data for 2020 from the Liberty monitor shows an annual average of 9.8 µg/m³ and a 24-hour average of 27.2 µg/m³, resulting in three-year averages of 11.2 and 32, respectively, both below the federal standards required to reach attainment. The 9.8 µg/m³ annual average for 2020 also meets the World Health Organization (WHO) air quality guidelines of 10 µg/m³. The county press release stated air quality was still on track to attain the federal standards in 2020 even without lower levels of pollution due to the pandemic, but staff attorney Ned Mulcahy was skeptical. “Record low emissions coincided with a record surge in unemployment in 2020. Bars, restaurants, schools, amusement parks, theatres and numerous other establishments spent unintended time closed. I don’t see how pretending 2020 was a typical year for anything – including air pollution – is helpful to the analysis.” “Plus,” he added, “Air quality in 2020 wasn’t exactly perfect.” Although, the county’s press release correctly noted that sulfur dioxide “registered a record low of 44 ppb, 31 points below the 75 ppb standard,” that value was only true for the Liberty monitoring site. The 2020 value at the North Braddock monitor was 65 ppb, which represents an *increase* from the 2019 value of 59 ppb. There were also two exceedances of the 75 ppb standard at North Braddock in 2020. In addition, double-digit violations of Pennsylvania’s 24-hour air quality standard for hydrogen sulfide continued in 2020 with a total of 26 exceedances at the Liberty monitor and two more at the North Braddock site, which only operated 22 days last year. “Clearly, there’s still work to do. Now more than ever we need ACHD to use its regulatory authority to ensure the health and welfare of residents is paramount moving forward,” Filippini said. “The health department is working on a series of regulations right now – rules about things like coke oven gas and episodic weather events that impact air quality – that could significantly help ensure healthier air in Allegheny County. We hope the department and County Executive Rich Fitzgerald will do all they can to make sure those regulations are as stringent as possible.” Editor’s Note: Here is some associated media coverage: Allegheny County Meets All Federal Air Quality Standards for First Time Ever, published by the Pittsburgh Post-Gazette For the First Time Ever, Allegheny County Meets Federal Air Quality Standards, published by State Impact All Allegheny County Air Quality Monitors Meet Federal Standards, a First in Two Decades, published by the Pittsburgh Tribune-Review #PM25 #LibertyMonitor #attainment #airqualitymonitors #AlleghenyCountyHealthDepartment #ACHD #airquality

Dear GASP Members, The time has come for dues-paying members to vote for nominees for election or reelection to our board of directors for terms running from 2021-2023. Here’s what you need to know: Casting your vote is easy: Check “yes” or “no” for each candidate and input your name, address, and email in the allotted space. Please complete your ballot by Feb. 28, 2021. Candidates will be elected by a simple majority of member votes. Election results will be announced at GASP’s annual business meeting slated for 7 p.m. March 3. For the safety of our board, staff, and members, this meeting will be held virtually. If you would like to attend, please RSVP by emailing rachel@gasp-pgh.org. The Zoom link will be emailed to you. “About half of our board is up for re-election presently, but GASP is eager to add some new voices and perspectives to our Board of Directors,” Executive Director Rachel Filippini said. “With this in mind we will be having another election later this year – so if you are interested in being considered please email your resume to rachel@gasp-pgh.org so we can follow up with you.” Editor's Note: The deadline to cast your vote has passed. Thanks to everyone who voted!

Chief Executive Rich Fitzgerald this week announced an investment in locally-generated clean energy, with Allegheny County entering into a 35-year agreement with Boston-based Rye Development to purchase renewable energy generated by a low-impact hydropower facility. Rye, which also has an office in Pittsburgh, will construct the facility on the Ohio River. In a press release Fitzgerald said for each year the agreement is in effect, Allegheny County will offset emissions equivalent to the entire electrical consumption of more than 3,400 households. Over the life of the agreement, the county’s purchases will offset more than 1 million metric tons of carbon dioxide-equivalent emissions, roughly equal to 2.6 billion miles driven in a typical passenger vehicle. “This announcement renews our commitment to the environment, our commitment to addressing climate change and is an investment in our future generations,” he said. The release touted the agreement as a “significant step forward in the county’s continued commitment to sustainability and renewable energy.” “We commend Allegheny County for its commitment to a large-scale renewable energy project and the leadership they’ve taken to address climate change locally,” GASP Executive Director Rachel Filippini said. The collaboration with Rye addresses one of the largest challenges to expanding access to renewable energy, particularly locally-generated clean energy: Capacity. The long-term commitment and partnership with Rye advance the goal of a community powered by 100 percent renewable energy. The hydropower facility will be located at the existing Emsworth Main Channel Dam on the Ohio River. The hydropower project is scheduled to begin construction in late 2021 and is expected to be operational as early as mid-2023. There will be no impact on the recreational use of the waterways as a result of the project. “Allegheny County continues to demonstrate its leadership with forward-thinking projects that benefit residents, the environment, and the local economy,” said Joylette Portlock, Ph.D., Executive Director of Sustainable Pittsburgh. “Investing in large scale renewable energy is a major step towards responsibly addressing climate change in southwestern Pennsylvania and invests in the health and the future of our communities.” Editor’s Note: You can read Allegheny County’s entire news release here. #airquality #AlleghenyCounty #alleghenycountyairquality #emissions

Allegheny County Health Department is now seeking public comment on several air quality permits. Two notices were published in late January with comments being accepted for the first batch of permits through Feb. 22. Another set of air quality permits will be out for public comment through March 15. Of particular interest are permits for U.S. Steel’s Mon Valley Works facilities. The installation permit for the proposed Co-Generation Plant at the Clairton Coke Works is among them. You can read the installation permit here and the installation permit review memo here. By way of background: The co-gen plant will use coke oven gas created at the plant to generate electricity. The plant should become electrically independent as a result of the project and may be able to export power to the grid. “Three of the plant’s six existing boilers will be shut down permanently by the project; the remaining three boilers will be operated only on a limited basis,” senior attorney John Baillie explained. Also out for public comment at the Clairton plant is the installation permit for its Pushing Emissions Control (PEC) Baghouse Replacement project. You can read that installation permit here and the installation permit review memo here. The PEC baghouse system controls pushing emissions from batteries 13-15, 19, and 20. U.S. Steel has maintained that the new system will reduce pushing emissions from those batteries – which are largely fugitive emissions – by capturing them and routing them through a baghouse and out of a stack. However, permitted emissions will increase as a result of the project. Another U.S. Steel installation permit is for an endless rolling caster at the Edgar Thomson facility. It can be viewed here and the associated review memo can be reviewed here. The endless caster and roller will replace two existing continuous strand casters at Edgar Thomson and likely render obsolete a hot strip mill at U.S. Steel’s Irvin Works. In addition, ACHD is also seeking public input on the draft installation permit for emergency generators at Edgar Thomson. You can read that installation permit here and the associated review memo here. “We think it is important to point out that while these permits are now in public comment, U.S. Steel continues to waver on their commitment to moving forward with them,” GASP Executive Director Rachel Filippini said, referencing recent media reports. GASP is currently reviewing the permits and will likely submit formal comments. We will share those when they are available. #USSteel #airqualitypermit #IrvinWorks #airqualitypermits #EdgarThomsonPlant #ClairtonCokeWorks #airquality #MonValleyWorks

This investigation is necessary to identify the nature and extent of hazardous substances in soils, sediment, and water at the property in anticipation of its cleanup and reuse. In addition, the investigation will help determine the sources of contamination and the extent of risk to the public health, safety, or welfare, or the environment, DEP said in a press release Monday. The Hazardous Sites Cleanup Act (HSCA) provides DEP with the funding and authority to conduct cleanup actions at sites where hazardous substances have been released. HSCA allows the DEP to investigate or address contamination in soil, surface water, sediment, and subsurface groundwater. HSCA also provides DEP with enforcement authority to force the persons who are responsible for releases of hazardous substances to conduct cleanup actions or to repay public funds spent on a DEP-funded cleanup action. “DEP is pursuing this site investigation to help identify potential contamination and harmful threats to human health and the environment,” said DEP Northwest Regional Director Erin Wells. “This investigation will provide a solid foundation to guide remediation and future redevelopment at the site.” With this announcement, DEP has begun the process of engaging DEP-approved contractors to begin the investigation. This process includes: preparing a scope of work meeting with the assigned contractor on-site then having the contractor prepare a work plan and cost estimate for the DEP’s review and approval prior to any investigation activities The United States Environmental Protection Agency (EPA), which began operations on-site in September 2020, has removed and disposed of wastes, demolished buildings, recycled appropriate scrap materials, and is actively mitigating risks associated with remaining tanks, containers, and piping posing the greatest threat to public health, welfare, and the environment. EPA’s removal actions at the Erie Coke, Inc. property are to be completed this summer. GASP, which worked closely with community group Hold Erie Coke Accountable to inform the Erie community about air quality issues in general, as well as Erie Coke’s history of environmental violations, lauded the announcement. “Erie Coke left a huge mess for the public to clean up,” GASP Executive Director Patrick Campbell said. “We hope DEP uses its authority to ensure the public doesn’t bear the financial burden for Erie Coke’s dereliction.” #HoldingErieCokeAccountable #ErieCoke #HazardousSiteCleanupAct #ErieCokecleanup #DEP #EPA

The Allegheny County Health Department on April 1 issued a Notice of Violation against U.S. Steel for hydrogen sulfide exceedances that occurred at the Liberty monitor. The NOV covers 25 exceedances, which occurred in 2020 and seven to date in 2021. The notice is the first step for any enforcement action, including civil penalties of up to $25,000 per violation per day, for sources. Hydrogen sulfide is a colorless gas most commonly recognized by its “rotten egg” smell. U.S. Steel has 14 days to schedule a meeting with ACHD to discuss the NOV before legal may proceed with further enforcement action. The last exceedance of the H2S standard occurred March 25 at the  North Braddock and Liberty monitors. There was also another insane one-hour value (0.081 ppm) at North Braddock – which is the second-worst one-hour value since Jan. 2016 for all ACHD h2s monitors. “GASP thanks ACHD for taking action on these hydrogen sulfide issues,” GASP Executive Director Rachel Filippini said. “They happen far too often, impacting the day-to-day lives of residents in the Mon Valley and beyond.” Check back – this is a developing story that will be updated when more information becomes available. #H2Sexceedances #hydrogensulfide #USSteel #ClairtonCokeWorks #airquality

Dear Fellow GASPers, Poet TS Eliot wrote, “To make an end is to make a beginning. The end is where we start from.” That resonates with us here at GASP, which is nearing the end of an era – one led by Rachel Filippini. For those who may not have heard: Rachel, who served as our executive assistant and education coordinator prior to ascending to the position of executive director 17 years ago, will depart GASP in mid-September to pursue the next chapter in her personal and professional life. We wish Rachel well and are so grateful for her service and dedication to GASP and its mission. Over the years, she spearheaded Allegheny County air quality legislation, increased GASP’s educational programming, creatively collaborated with myriad organizations to increase awareness, and continued to keep air pollution issues in the public eye. She worked hard to help people from all walks of life better understand how air quality impacts them, and how to take action in their own communities. Her steadfast commitment to improving the air we all breathe spurred real change in Allegheny County and beyond. The end of Rachel’s tenure marks the beginning of a new era at GASP, one during which we will work to meet the goals set forth in an ambitious strategic plan initiated earlier this year. We are currently screening candidates and will keep you posted as the process proceeds. While Rachel wishes she could see and hug all of you at a big going-away celebration, given current pandemic realities, it’s just not in the cards. Instead, she asks GASP supporters who wish to honor her to consider making a donation to help our new leader hit the ground running. Starting this new era on sound financial footing will ensure our ability to continue pushing for updated coke oven regulations, strong episodic weather rules, and carry on our important education, legal, and watchdog work. Big or small, all donations are graciously accepted. You can make a one-time or recurring donation in honor of Rachel’s work and legacy on our website via PayPal or by check via snail mail. Our address is 1133 S Braddock Ave, Pittsburgh, PA 15218. If you would prefer, our office manager Kathy Lawson can process your credit card donation over the phone – just email her at kathy@gasp-pgh.org. We look forward to entering this new era with you. Warmest Regards, GASP President Jonathan Nadle

Clairton Park came alive Saturday with a unique blend of hip hop and puppetry thanks to Tarish “Jeghetto” Pipkins, an internationally renowned artist and puppeteer who performed a special homecoming show – one that thrilled both adults and children alike. GASP was honored to sponsor the show, which featured puppets Pipkins crafted using mostly recycled materials. And those in attendance didn’t have to settle for a view from afar: Jeghetto climbed off the stage and walked through the audience to show off the creations and help folks understand how they worked. But Pipkin’s puppets weren’t the only ones that wowed last weekend: GASP’s own Dirty Gertie the Poor Polluted Birdie (played by our friend Dave English, a local artist, educator, and puppeteer), flagged by one of our education specialists, was on hand to help those in attendance understand a little more about the importance of clean air. PS: We want to extend a HUGE thank you to the fine folks at Hollowood Music in McKees Rocks, who graciously lent us the stage on which Jeghetto performed. Thanks, Hollowood Music! If you missed it, here are some photos and video clips from the big day: #airpollution #TarishPipkins #DirtyGertie #DaveEnglish #Jeghetto #Clairton #airquality

Even those of us who don’t live near or downwind of an industrial source of air pollution 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. Not familiar with smoke reading? Then let’s take a step back to explain: “Smoke readers” is a general term for volunteers 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 Rachel Filippini noted. Our 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 reading visible emissions at the facilities that are of concern to them. “The reality is local inspectors can’t be at every facility at all times,” she said. “Readings from volunteers who are trained and certified as smoke readers  may help increase regulatory scrutiny on air polluters.” 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 put on by Eastern Technical Associates – but please know spots for this opportunity are extremely limited. Once your training is complete, the GASP team can pick up from there to get you started with actual observations in your community. The next two-day training is scheduled for late September. The first session is a live webinar held at 9 a.m. every Monday and Tuesday. Participants will spend the second session in the field on either Sept. 29 or Sept. 30. The field instruction registration begins at 8 a.m. and consists of multiple hourly field observation periods called runs. Complete one hourly observation successfully and you are done and will receive certification. Certification lasts six months. You can get more details on the Eastern Technical Associates website or email sue@gasp-pgh.org for details. #SmokeReaders #airpollution #emissions #AlleghenyCountyHealthDepartment #ACHD #airquality #EasternTechnicalAssociates #SmokeSchool