State Implementation Plan for Sulfur Dioxide Open for Public Comment

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Parts of Allegheny County (mostly in the Mon Valley) are not achieving the national one hour sulfur dioxide (SO2) ambient air standard of 75 parts per billion. The Allegheny County portion of the State Implementation Plan (SIP) to achieve this standard can be found on the Allegheny County Health Department Air Program website.

Anyone may make comments on the Allegheny County portion of the Sulfur Dioxide State Implementation Plan. However, Mon Valley residents should be particularly interested as the Non-Attainment Area for the 2010 sulfur dioxide standard, which consists of many communities in the Monongahela Valley, namely: City of Clairton, City of Duquesne, City of McKeesport, Borough of Braddock, Borough of Dravosburg, Borough of East McKeesport, Borough of East Pittsburgh, Borough of Elizabeth, Borough of Glassport, Borough of Jefferson Hills, Borough of Liberty, Borough of Lincoln, Borough of North Braddock, Borough of Pleasant Hills, Borough of Port Vue, Borough of Versailles, Borough of Wall, Borough of West Elizabeth, Borough of West Mifflin, Elizabeth Township, Forward Township, and North Versailles Township.

There will be a public hearing to take testimony on the proposed revision on Thursday, April 6, 2017, at 6:00 p.m. Speakers must sign up 24 hours in advance and should call 412-578-8120 to secure a speaking slot. Speakers will have up to five minutes to deliver their comments and should bring a written copy of their comments to the hearing.

Hearing location:
Allegheny County Health Department (ACHD)
Clack Health Center Bldg. 7
301 39th St.
Pittsburgh, PA 15201

Let the Board of Health know you want a strong plan to reduce sulfur dioxide levels to provide for a healthy environment and community in the Mon Valley!

You may also make written comments until 11:59 p.m. April 11, 2017. See the Air Program website for mailing & email addresses.

The following are issues of concern to GASP that you may want to keep in mind as you prepare your comments.

Enforceability

A State Implementation Plan must identify the limitations that will be required in order to attain and maintain the National Ambient Air Quality Standards. Further, those limitations must be adopted as rules or regulations of the local air agency or incorporated into federally enforceable Title V Operating Permits. (See 40 Code of Federal Regulations 51.281)

The 2017 Proposed Revision to the Allegheny County Portion of the Pennsylvania State Implementation Plan identifies reduction in the sulfur content of the gas combusted by U.S. Steel’s Mon Valley Works as a control strategy, but does not translate that strategy into rules, regulations, or permit conditions as it must.

Work Practice Standards, Record Keeping, Reporting Requirements

The SIP does not include work practice standards, record keeping, or reporting requirements where necessary to ensure Control Strategy emission levels (See 40 C.F.R. Chapter I Part 51 Subpart BB Appendix V 2.2(g)). For example, the Vacuum Carbonate Units have no monitoring, record keeping, or reporting descriptions in the proposed SIP. Assurance that hourly data is monitored and adjustments will be made if necessary will help to maintain required emission limits.

Contingency Measures

The SIP does not contain contingency measures to be put in place to further reduce sulfur dioxide if the present Plan does not achieve the SO2 standard by the Attainment Date. The Plan has several control strategies that are in the process of being built but are only required to be built by October 4, 2018! Some control strategies are still in discussion. There have been two exceedances already of the 1-hour sulfur dioxide standard this year (2017) at the Liberty monitor. (Note: data is not fully validated/certified for 1st quarter 2017.)  The Mon Valley area has many inversions that drive up pollution levels. There must be contingency measures in the Plan in case attainment is not reached.

Hotspot Ambient Monitor

In order to assure attainment in all of the non-attainment area, as is required, the plan should include a monitor located at or near the modeled “Hotspot” area, Grandview Golf Course, in order to assure attainment in the future. Especially as this is an area of outdoor exercise and exertion including an elderly population, impacted by nearby Edgar Thomson Works, monitoring is warranted. (See 40 C.F.R Part 58, Appendix D, Section 1.1.1)

Plan Should Not Have Averaging

There should be no averaging, especially the possible 30 day averaging period. Averaging allows some higher sulfur periods (in H2S fuel or SO2 emissions, depending on what is averaged ultimately). The non-attainment area is highly prone to inversions, which could make attainment more difficult under any control strategy. Details of a possible averaging plan are not known but the allowance of averaging to help achieve attainment of the 1-hour SO2 standard seems not helpful to the attainment goal.

–Sue Seppi, Project Manager

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