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The ACHD Hearing is Wednesday, January 10, 2024, at 6:00 pm. Register here to give your trestimony.
This blog post will cover these topics:
1. Background of Clairton Coke Works
2. What is a Title V Permit?
3. Timeline of Events to Date
4. Link to Draft Permit Document & VCAN"s Outline of Permit
5. Issues Allegheny County Health Department Seeks Public Comment on 1/10/24
This permit process is complicated, with many pieces to consider. If your statements stray from these specific issues, our experience testifying at previous ACHD Title V hearings, if your comments are not unique and do not mention a technical component of the Title V permit, your comments will not be considered by ACHD or the EPA. As a result, we have scheduled a public meeting to make a presentation and then discuss these issues with residents at:
VCAN Title V Pre-Hearing Meeting at 6 pm - 7:30 pm
CEDCC Building
282 St. Clair Avenue, Clairton, PA 15025.
1. Background on Clairton Coke Works
“The U.S. Steel Mon Valley Works Clairton Plant in Allegheny County, Pennsylvania is the largest by-products coke plant in the United States. The facility was built in 1901, and U.S. Steel has operated the facility since 1904. The facility operates seven coke batteries, seven quench towers, and six boilers, among other emission units. The facility produces approximately 13,000 tons of coke per day from the distillation of more than 18,000 tons of coal.
The coke by-products plant of the facility produces approximately 145,000 gallons of crude coal tar, 55,000 gallons of light oil, 50 tons of anhydrous ammonia, and 35 tons of elemental sulfur each day from the coke oven gas produced by the coking process. The coke produced is then used in blast furnace operations in the production of molten iron for steel production.
The Clairton facility is a major source of carbon monoxide (CO), nitrogen oxides (NOw), particulate matter (PM), PMio, PM2.5, sulfur dioxide (SO2), volatile organic compounds (VOCs), and Hazardous Air Pollutants (HAPs).”
Quote from US Environmental Protection Agency Administrator Michael Regan’s September 21, 2023 Order, page 6. .
Cindy Meckel VCAN Steering Committee member
2. What is a Title V Permit?
The EPA has identified “hazardous air pollutants” whose releases must be controlled by government regulators. The Federal Clean Air Act (CAA) calls individuals or businesses that produce these chemicals “sources". These sources must be “permitted” by the EPA to release a maximum amount each year. Title V of the CAA spells out what information has to be contained within each permit that lasts five years. As a result, it is called a Title V Permit.
Across our country, it is state government agencies that enforce the terms of the Title V permit on a day-to-day basis. EPA and state governments create a State Implemented Plan (SIP). Pennsylvania’s enforcement agency in our SIP is the PA Department of Environmental Protection (PA DEP). Pennsylvania also has its statute, the Pollution Control Act, that restricts the release of hazardous air pollutants inside Pennsylvania.
Pennsylvania law is unique because our two largest counties (based on population), Philadelphia and Allegheny, were primarily responsible for enforcing the CAA and Pollution Control Act inside their borders. The Allegheny County Health Department (ACHD) has the responsibility to negotiate and enforce Title V Permits inside our county. As a result, ACHD is called the “primary air pollution control enforcement agency.” Allegheny County has its law restricting hazardous air pollutants in our county called "Air Pollution Control Regulations'' or "Article XXI''.
As the Federal Government’s agency, EPA oversees and has the final say on the entire Title V process.
Here are the federal, state, and local air quality agencies and links to the three laws they each are responsible for enforcing:
US Environmental Protection Agency – Overview of the Clean Air Act and Text
PA Department of Environmental Protection- Air Pollution Control Act, Purdons’ Title 35 Health & Safety; Chapter 23
Allegheny County Health Department – Rules & Regulations XXI
Kim Meacham Friend of VCAN
3. Timeline of Draft Permit Events to Date
In 2012 U.S. Steel first obtained a Title V permit for Clairton Coke Works (CCW).
September 26, 2016, U.S. Steel applied for renewal of CCW’s Title V permit.
January 13, 2022, ACHD published notice of draft permit, subject to a public comment period that ran until February 28, 2022, and was extended to March 15, 2022.
September 28, 2022, ACHD submitted the Proposed Permit to EPA 45-day review for approval. ACHD withdrew this Permit and then resubmitted the Second Proposed Permit to EPA for its 45-day review and approval on November 16, 2022.
January 3, 2023, EPA's 45-day review period ended with no objections. As a result, ACHD’s Second Proposed Permit for CCW was considered approved.
March 6, 2023, Environmental Integrity Project, Penn Environment & Clean Air Council filed Claims A through H as Objections with EPA to Second Proposed Permit. Group Against Smog & Pollution (GASP) filed Claim I with EPA as an additional Objection to the Second Proposed Permit.
September 21, 2023, EPA Order by Administrator Regan accepted some Objections & denied other Objections, forcing ACHD to rewrite the Second Proposed Permit.
October 11, 2023, Tribune-Review Article “Environmental Groups Claim Victory in EPA Ruling on US Steel Plant in Clairton”
ACHD has now revised the Second Proposed Permit to follow the EPA October 2023 Order. (We believe these required revisions have been written into a December 6, 2023, TVOP Review Memo document on their website.
ACHD has scheduled a Hearing in Clairton on January 10, 2024, to collect public comment on the revised Second Proposed Permit.
Art Thomas VCAN Steering Committee member
You can read the official Draft Permit on ACHD's website using the link above. You can also read the Outline written by Qiyam Ansari, VCAN Steering Committee Chair, of the Permit which is posted on the VCAN website.
5. Issues ACHD is seeking Public Comment on January 10, 2024
Emission Limits and Types: Levels for various pollutants, including particulate matter, sulfur dioxide (SO2), nitrogen oxides (NOx), and volatile organic compounds (VOCs). These pollutants can significantly impact air quality and may exacerbate asthma symptoms.
Operational Practices: The facility's operational practices, particularly those related to combustion, use of fuels, and processing methods, can affect the type and amount of pollutants released into the atmosphere. Operational malfunctions or non-compliance with these practices could lead to increased emissions.
Leak Detection and Repair: Incomplete or delayed repair of leaks in equipment could lead to unintended emissions of VOCs and other hazardous air pollutants, which could be asthma triggers.
Monitoring and Testing Protocols: The frequency and effectiveness of monitoring and testing for emissions play a crucial role in ensuring compliance with permitted levels. Inadequate monitoring could result in undetected or underreported emissions.
Record Keeping and Reporting: Accurate record-keeping and timely reporting of emissions data are essential for regulatory compliance and public transparency. Any lapses in these areas might obscure potential air quality issues.
Fugitive Dust and Vehicular Traffic: Operations involving the handling of coal and coke, as well as vehicular traffic within the facility, can contribute to particulate matter in the air. Dust control measures are crucial in mitigating this risk.
This first tip should be a juicy one. It’ll keep your readers with you.
Tom Bailey VCAN Steering Committee member & Secretary
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