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By the Numbers: A Look at Allegheny County Health Department, DEP Title V Permit Backlog Reduction Efforts

In September 2016 we blogged about the backlogs of applications for new and renewed operating permits for major sources of air pollution that existed in Allegheny County (where such sources are regulated by the Allegheny County Health Department (ACHD)) and the Pennsylvania Department of Environmental Protection’s (DEP) Southwest Regional Office (SWRO).

Operating permits for major sources of air pollution are required by Title V of the Clean Air Act, and thus are commonly called Title V Operating Permits.

In March 2018, we updated that blog and expanded our research to sources permitted by DEP’s other five regional offices. Because Pennsylvania’s Environmental Quality Board has just proposed to amend the fee schedule for permits issued by DEP’s Air Quality Program, we decided to check back to see the extent to which ACHD and DEP have resolved the backlogs that existed in 2016 and 2018, and thus the extent to which the existing fee schedule might be inadequate to fund the Program’s permitting function.

Here’s what things looked like last year:

Agency or Regional Office Number of Major Sources Number of Major Sources with Backlogged or Unissued Title V Operating Permits Percentage of Major Sources with Backlogged Title V Operating Permits
ACHD 27 8 30%
SWRO 71 14 20%
NWRO 61 3 5%
NCRO 65 0 0%
SCRO 135 1 <1%
NERO 69 9 13%
SERO 94 2 2%

Here’s what we found when we updated our research this year:

There are still two major sources in Allegheny County that have never been issued Title V Operating Permits – Allegheny Ludlum’s Brackenridge Works and Eastman Chemical.

Additionally, it bears mention that there are also two known non-major sources in Allegheny County that are (or were) required to have a Title V Operating Permit that have never had one:  Harsco Metals and Alcosan – in certain situations, the Clean Air Act requires a non-major source to obtain a Title V Operating Permit; Harsco and Alcosan each fall into such a situation.

We are omitting such non-major Title V sources from this analysis to try to ensure that the comparisons we make between ACHD and the various DEP regional offices are valid.

With respect to Title V Operating Permits for major sources in Allegheny County, ACHD has failed to act on renewal applications for five such sources within 18 months as its regulations require:

ACHD LATE TITLE V OPERATING PERMIT RENEWALS
(AS OF 2/13/2018)

FACILITY LOCATION Renewal Application Submitted Last Permit Expired
Buckeye Pipe Line/Coraopolis Terminal Moon Township 8/8/2007 2/10/2008
NRG Power Brunot Island (Pittsburgh) 6/24/2015 2/15/2016
Sunoco Pittsburgh Terminal Pittsburgh 12/30/2015 6/30/2016
Allied Waste Imperial Landfill Findlay Township 1/13/2016 10/13/2016
U.S. Steel Clairton Plant Clairton Boro 9/26/2016 3/26/2017

It bears mention that in early 2019 ACHD published for public comment a draft Title V Operating Permit for the Buckeye Pipe Line/Coraopolis Terminal. There is thus reason to think that site will be removed from ACHD’s list of backlogged renewals relatively soon.

For purposes of air quality permitting, DEP’s Southwest Region now includes sources in Beaver, Cambria, Greene, Somerset, Washington, and Westmoreland Counties.  Responsibility for administering the Title V permitting program for sources in Armstrong and Indiana Counties was transferred from the Southwest Region to DEP’s Northwest Region in early 2019.

We currently count 61 major sources in the reduced-size Southwest Region, with 15 of those sources having renewal applications for operating permits that have been pending for more than 18 months.

SWRO LATE TITLE V OPERATING PERMIT RENEWALS
(AS OF 2/13/2018)

FACILITY LOCATION Renewal Application Submitted Last Permit Expired
Arden Landfill Chartiers Twp., Washington County 11/7/2005; 9/18/2015 5/7/2006
Consolidated Coal Bailey Prep Plant Richhill Twp., Greene County 5/25/2006;
1/29/2014
11/28/2006
Flexsys Monongahela Plant Carroll Twp., Washington County 7/3/2006;
9/25/2012
1/3/2007
Ebensburg Power Co. Cambria Twp., Cambria County 8/17/2006 2/19/2007
Allegheny Valley Connector LLC Laurel Ridge Station Jackson Twp., Cambria County 5/11/2007;
1/2/2014
1/14/2008
U.S. Gypsum/NGC Industries Aliquippa, Beaver County 7/27/2009 1/27/2010
Allegheny Energy Gans Power Station Springhill Twp., Fayette County 7/20/2009 1/27/2010
Texas Eastern Delmont Compressor Station Salem Twp., Westmoreland County 9/17/2012 4/29/2013
Equitrans Pratt Compressor Station Franklin Twp., Greene County 4/19/2016 10/20/2016
General Carbide Corp. Hempfield Twp., Westmoreland County 6/2/2017 12/13/2017
Allegheny Technologies Midland Midland, Beaver County 1/7/2017 9/6/2017
Latrobe Specialty Metals Latrobe, Westmoreland County 7/3/2017 1/4/2018
Dynergy Fayette II German Twp., Fayette County 6/19/2017 1/30/2018
FirstEnergy Bruce Mansfield Plant Shippingport Boro, Beaver County 6/1/2017 4/2/2018

DEP’s Northwest Region (“NWRO”) now includes Armstrong and Indiana Counties for Title V permitting purposes, as well as Butler, Clarion, Crawford, Elk, Erie, Forest, Jefferson, Lawrence, McKean, Mercer, and Venango Counties.

We count 73 active major sources of air pollution in the Northwest Region.  Five of those 73 facilities have had renewal applications for their Title V Operating Permits pending for more than 18 months:

Facility Location Permit Application Submitted Last Permit Expired
Armagh Compressor Station West Wheatfield Twp., Indiana County 6/28/2012 7/31/2012
Armstrong Power, LLC South Bend Twp., Armstrong County 3/14/2014; 2/26/2015 9/29/2014
Homer City Generation Center Twp., Indiana County 5/4/2017 11/16/2017
Seward Generating Station East Wheatfield Twp., Indiana County 7/3/2017 2/11/2018
Erie Coke Erie, Erie County 8/28/2017 3/26/2018

It is worth noting that four of those five sources were among those transferred from the Southwest Region in early 2019.

DEP’s Northcentral Region (NCRO) includes Bradford, Cameron, Centre, Clearfield, Clinton, Columbia, Lycoming, Montour, Northumberland, Potter, Snyder, Sullivan, Tioga, and Union Counties.

We counted 63 major sources of air pollution in the Northcentral Region. Although there are no sites in the region with renewal applications that have been pending for more than 18 months, two sites in the region (if they are active) may be operating without having submitted required applications for operating permits, which would seem to be violations of the Clean Air Act and Pennsylvania Air Pollution Control Act.

Facility Location Permit Application Submitted Last Permit Expired
Springs Window Fashions Clinton Twp., Lycoming County No application submitted 12/29/2015
Tennessee Gas Pipeline, Wyalusing Compressor Station Wyalusing Twp., Bradford County No application submitted 3/15/2018

DEP’s Northeast Region (NERO) includes Carbon, Lackawanna, Lehigh, Luzerne, Monroe, Northampton, Pike, Schuykill, Susquehanna, Wayne, and Wyoming Counties.

We counted 62 active major sources of air pollution in those counties, three of which have had applications for their Title V Operating Permits pending for at least 18 months:

Facility Location Permit Application Submitted Last Permit Expired
Keystone Cement Co. East Allen Twp., Northampton County 3/7/2006 8/3/2006
Hercules Cement Stockertown Plant Stockertown, Northampton County 12/15/2011 6/29/2012
Ingenco Wholesale Power Pine Grove Twp., Schuykill County 4/2/2016; 7/6/2015 11/19/2015

DEP’s Southcentral Region (SCRO) includes Adams, Bedford, Berks, Blair, Cumberland, Dauphin, Franklin, Fulton, Huntington, Juniata, Lancaster, Lebanon, Mifflin, Perry, and York Counties. We counted 125 active major source of air pollution in these counties, only one of which has had a renewal application for a Title V Operating Permit pending for more than eighteen months:

Facility Location Permit Application Submitted Last Permit Expired
Calpine Mid Merit, LLC Peach Bottom Twp., York County 6/22/2017 1/20/2018

DEP’s Southeast Region (SERO) includes Bucks, Chester, Delaware, and Montgomery Counties for purposes of permitting sources of air pollution (Philadelphia’s Air Management Services administers the Title V permitting program for facilities located in Philadelphia).

We counted 94 active major sources of air pollution in the Southeast Region, two of which have had renewal applications for Title V Operating Permits pending for more than 18 months:

Facility Location Permit Application Submitted Last Permit Expired
Superior Tube Co., Collegeville Facility Lower Providence Twp., Montgomery County 1/26/2016 8/3/2016
Sunoco Hog Island Marine Terminal Tinicum Twp., Delaware County 3/17/2016; 6/14/2017 10/28/2016
U.S. Steel Fairless Hills Falls Twp., Bucks County 5/8/2017 11/19/2017

This chart summarizes the performance of all the regions discussed above, as well as the performance of ACHD and DEP’s Southwest Region as discussed in our earlier blog:

Agency Number of Major Sources2018/2019 Number of Major Sources with Backlogged or Unissued Title V Operating Permits2018/2019 Percentage of Major Sources with Backlogged Title V Operating Permits2018/2019
ACHD 27/27 8/7 30%/26%
SWRO 71/61 14/15 20%/25%
NWRO 61/73 3/5 5%/7%
NCRO 65/63 0/0 0%/0%
SCRO 135/125 1/1 <1%/<1%
NERO 69/62 9/3 13%/5%
SERO 94/94 2/2 2%/2%

Thus, in the last year, the permit backlog at DEP’s Southwest Region appears to have gotten worse, while the backlogs at ACHD and DEP’s Northeast Region have been reduced.

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