The U.S. Environmental Protection Agency (EPA) recently announced a new May 1 deadline to apply for funding under its Community-Scale Air Toxics Ambient Monitoring grant program, giving the Allegheny County Health Department (ACHD) a chance to submit a project proposal.
Given that the grant guidelines state, “(A)ir toxics of particular interest to EPA in this solicitation include benzene,” and that U.S. Steel’s Clairton Coke Works accounted for 80 percent of all benzene emissions in Allegheny County in 2018 (a total of 15.1 tons per Department of Environmental Protection data), GASP has a project in mind.
More About the Grant Program & Why it has Benzene Monitoring at Clairton Coke Written all Over it.
By way of background, EPA anticipates awarding 10 to 20 grants, up to a maximum of $750,000 for any one project proposal, to assist air agencies in identifying and characterizing air toxics, also known as hazardous air pollutants (HAPs), through work that falls into one of four categories:
characterizing the impacts of air toxics in a community;
assessing the impacts of air toxics from specific sources;
programs that evaluate new and emerging testing methods for air toxics; and,
programs that analyze existing air toxics data and develop or enhance analytics, modeling, or implementation tools
Federal grant applications can demand a lot of detail, but here ACHD’s administrative burden would be light given that the DEP developed a benzene-sampling program around the fence line of Erie Coke’s facility this past summer. In addition, GASP believes that submitting a grant application for additional benzene monitoring around Clairton Coke based entirely on the DEP’s existing program would have a high probability of being funded.
In fact, such a program would resoundingly check all four boxes in EPA’s criteria:
The data collected would help ACHD better understand the impacts of benzene on the communities surrounding Clairton Coke;
This monitoring program would assess the impact of benzene from a specific source;
The DEP’s monitoring program adapts an existing method of sampling used for petroleum refineries. In addition, sampling at Clairton Coke’s fence line would supplement and / or validate benzene data that is already being collected intermittently in the County; and,
This monitoring data would allow ACHD to better-assess exposure models for Clairton emissions and the efficacy of the coke oven regs we hope to see soon.
Why the Focus on Benzene?
To understand the importance of monitoring benzene, you first have to understand a few things about this hazardous air pollutant, its impact on human health, and what the local sources of benzene are.
The EPA first listed benzene as a hazardous air pollutant (HAP) under Section 112 of the Clean Air Act in 1977 based on reports “strongly suggest(ing) an increased incidence of leukemia in humans exposed to benzene.”
While the EPA has determined that average benzene concentrations of one part-per-billion (ppb) can potentially cause one in 100,000 excess cases of cancer, the World Health Organization (WHO) has stated that as a carcinogen, “no safe level of exposure (to benzene) can be recommended.”
While several agencies agree that long-term exposure to benzene concentrations less than 1 ppb are unlikely to have non-cancer effects, the U.S. Agency for Toxic Substances and Disease Registry believes that exposure to levels at or more than 9 ppb for even one day can be harmful to your health. ACHD monitor data showed a benzene concentration of 12.74 ppb at the Liberty Monitor site in December 2018.
In fact, ACHD measures benzene and other toxic air pollutants at two sites in the County: downtown Pittsburgh and at the Liberty Monitor (air toxics monitoring was discontinued at the Avalon monitoring site last year). Without variation, the Liberty Monitor shows the highest readings.
According to the 2018 Allegheny County Air Quality Annual Report, the annual average benzene concentration in downtown Pittsburgh at Flag Plaza was 0.37 ppb. The data show—and ACHD’s Report confirms—that over the same period, benzene barely registered in Avalon but was 0.96 ppb at the Liberty Monitor.
While ACHD air quality monitor data show concentrations of benzene well below Occupational Safety and Health Administration (OSHA) workplace safety levels at the Liberty Monitor site, it is still above acceptable risk levels for ambient air.
For all of these reasons, GASP believes it’s imperative for ACHD to expand benzene monitoring so it can better understand the potential human exposure to emissions from Clairton Coke, which is far and away the largest stationary source in Allegheny County.
Understanding DEP’s Benzene Monitoring in Erie & Why ACHD Should Emulate It
For those who might be unfamiliar, DEP this past July announced that it would begin conducting air quality monitoring near the now-shuttered Erie Coke plant and throughout the surrounding area to assess health risks to the general public.
The monitoring came in the wake of several enforcement actions that required Erie Coke to address numerous, ongoing violations.
DEP’s monitoring program focused on the so “BTEX” compounds (benzene, toluene, ethylbenzene, and xylene) because they are related to coke productions specifically. Monitor sites were placed in 13 locations along the perimeter of the Erie Coke facility and at four locations in the community.
DEP regularly updates its website with those sampling results – including the full lab reports – along with maps showing where there were high concentrations. This is a level of transparency that GASP greatly appreciates and believes could and should be mirrored here in Allegheny County.
If not now, when?
ACHD simply must develop a plan to monitor benzene near Clairton Coke. Assessing such risks is absolutely part of the department’s public health mission. For all of these reasons and more, ACHD must take advantage of a funding opportunity that would not only provide for much-needed data and analysis of a harmful air toxic, it would also preserve ACHD funds for other core work and projects that directly benefit the communities most affected by local air pollution.
“Grant funding is never a certainty, but to just not apply, to let this opportunity pass our region by at a time when it is continually assigned failing grades for air quality is incomprehensible and bordering on fiscally irresponsible,” GASP Executive Director Rachel Filippini said. “If our regulators want to better control emissions and in turn better protect public health then they should apply for this funding. The health department’s counterpart at the state level is undertaking this kind of monitoring right now and implementing it here would be a perfect fit for ACHD and the community.”