Air Quality Review 2023

2023 showed further advancement in Allegheny County air quality. For the fourth year in a row the county continued the trend of fully meeting the National Ambient Air Quality Standards (NAAQS) for all criteria pollutants. This allowed the program to submit the SO ₂  Redesignation Request and Maintenance Plan to the Pennsylvania Department of Environmental Protection (PA DEP), this plan is then submitted to the US Environmental Protection Agency (EPA) for approval. 

The amount of outstanding permits and enforcement actions has reduced even further from previous years in addition to new enforcement actions being issued. Further, the Allegheny County Health Department (ACHD), in partnership with PennEnvironment and the Clean-Air Council, reached a settlement with US Steel for the 2018 fire. This settlement includes a $5 million penalty and numerous corrective actions. The monitoring network went through a system-wide improvement process and expanded its network even further. The network continues to be one of the largest air monitoring networks in the nation.  

This work is not possible without the dedicated staff of 60 that focus on improving the air quality of Allegheny County every day. They continued their work even while undertaking a major office move from Lawrenceville to the Northside.

Some additional achievements to highlight for 2023 are:

• $2.3 million of Clean Air Funds granted to seven projects to improve air quality in the county, with emphasis in the Mon Valley
• $10 million award from the EPA Targeted Airshed Grant for the Pittsburgh Regional Transit (PRT) Electric Buses and Infrastructure project with a focus on routes through the Mon Valley
• Conducted over 1,500 monitoring quality assurance checks and collected and tested over 2,500 air quality samples
• Conducted special studies began on PM _2.5  contribution and smoke impacts from Canadian wildfires

Geoff Rabinowitz, DPA Environmental Health Deputy Director

The Allegheny County Air Quality Program is a county-level regulatory agency that works closely with the PA DEP Air Quality Program. The regulatory power of the ACHD is only within county limits for point source pollution. Pollution standards are set by the EPA and the PA DEP which are incorporated into Allegheny County regulation,  Article XXI: Air Quality Rules and Regulations.  The ACHD can and does have more rules and regulations than the federal and state level, but does not and cannot contradict any federal or state law.

Many activities are involved with being a environmental regulatory authority. There are four sub-programs within Air Quality that accomplish the work: Monitoring and Source Testing, Planning and Data Assessment, Permitting and Engineering, and Compliance and Enforcement.

•  Monitoring and Source Testing  provides data collection for over 100 pollutants and quality assurance/repair at a dozen monitoring sites across the county, provides source testing oversite, and studies air composition.
•  Planning and Data Assessment  analyzes monitored, meteorological and emissions inventory data. This section also prepares reports for state and federal entities, writes regulation, manages the  Clean Air Fund  and applies for grants. Through this sub-programs efforts, in 2023 the county was awarded $10 million from the EPA to replace PRT diesel buses with electric buses.
•  Permitting and Engineering  issues operating and installation permits for designated point source pollution facilities.
•  Compliance and Enforcement  issues permits for asbestos remediation, abrasive blasting and open burning. They are also responsible for ensuring compliance with Article XXI, assessing enforcement actions, and responding to resident complaints.

Working toward air quality improvements requires a multipronged approach. Through monitoring, permitting, inspections, and compliance enforcement there is constant work done to keep the county compliant with Article XXI.

Permitted facilities in Allegheny County are required to regularly have air emissions testing done on sources of air pollution. The Air Monitoring and Source Testing Program reviews and approves testing protocols and test reports for sources of point source pollution. Each facility has a schedule for how often their source testing needs to be done. Some facilities have tests that need to be preformed annually while others are tested every two or five years. In 2023 the team attended nearly 80 source tests performed by independent third parties.

Major sources, also known as  Title V facilities , are defined by the EPA and Article XXI as any source with the potential to emit more than:

• 50 tons per year of Volatile Organic Compounds (VOCs)
• 100 tons per year of particulate matter (PM), nitrous oxides (NO _x ), carbon monoxide (CO), or sulfur dioxide (SO ₂ )
• 10 tons per year of any single Hazardous Air Pollutant (HAP) or more than 25 tons per year of any combination of HAPs

Minor sources are those which release less than the major source pollutant threshold. A synthetic minor source is a facility with the ability to exceed the major source threshold, but who take a federally enforceable permit limit to operate under the major source pollution minimum emissions threshold, effectively making it a minor source.

New permits are for facilities that have never received an operating permit and for which this is their first operating permit. These are either new facilities, or those with outstanding permits. Facilities are renewed every five years after receiving their initial operating permit.

Installation permits are for new construction or changes to existing operations that would significantly change emission output. The conditions for all of a facility’s installation permits are incorporated into their operating permit.

The ACHD has delegated authority from the EPA and PA DEP to perform inspections on all regulated facilities in Allegheny County. Enforcement staff conducted 979 onsite inspections in 2023 to ensure facilities and work sites complied with Article XXI and the terms of their permits.

Compliance inspections for major, synthetic minor, and minor sources are done in line with Clean Air Act's  Compliance Monitoring Strategy Policy . These inspections are often multi-day or week efforts. A Full Compliance Inspection is made of a series of various inspections. This includes: an onsite inspection of the facility and its equipment, reviews of compliance certifications, semiannual reports, stack testing reports, emission inventory submittals and other monitoring and record keeping.

Other compliance inspections include inspections for asbestos abatement projects of which there were 627 permitted in 2023. Compliance officers will also investigate permitted abrasive blasting sites, permitted burns and resident complaints about open burning to ensure that burning is properly set back from buildings, and that materials and size of fire are compliant with Article XXI.

Enforcement actions are taken when a facility, open burn, or work site for asbestos or abrasive blasting violates Article XXI. The goal of assessing penalties is to compel compliance. All penalties are calculated based on the  Civil Penalty Policy . Many enforcement actions throughout the year are based on previous years violations as some may go through litigation.

Enforcement Actions: 30 assessed, 15 resulting in penalties of $2,842,471 Major Source penalties: $2,529,175 Asbestos, Abrasive Blast, and Open Burn: $313,296

The Air Quality Program is constantly learning and developing. This includes data analysis, studies, program development, and investigating resident complaints. Below are highlights of this work from 2023.

The Atmospheric Science and Chemistry Measurement Network (ASCENT)

The Monitoring and Source Testing Program launched the  Atmospheric Science and Chemistry Measurement Network (ASCENT)  at the Lawrenceville monitoring station. In partnership with Carnegie Mellon University and the National Science Foundation Mid-Scale Infrastructure program this network uses four highly advanced air monitors to identify the chemical make up of microscopic particles in the air.

Fine particles have an impact on the climate by changing how heat from the sun is absorbed or scattered, this changes how clouds form and precipitate. Fine particulate matter (PM _2.5 ) can also harm human health in high concentrations. The goal of the ASCENT is to gain a more complete understanding of the sources, chemical and physical properties, and dynamics of fine particulate matter. This allows for more accurate evaluation and prediction of how fine particulate matter impacts climate, human health, and ecosystems.

The Air Quality Program implemented updated Coke Oven Inspection Rules in 2023. The updated regulations strengthened the provisions of Article XXI relating to coke ovens and aligned them with the requirements of the Clean Air Act and the Pennsylvania Air Pollution Control Act.

Further development was made on the Regulated Entities Portal (REP) in order for launch in early 2024. This software is customized to track regulatory requirements and communications between the ACHD and regulated facilities and projects. The REP portal allows facilities to access invoices, pay annual maintenance fees, submit emission inventories, and pay emission inventory fees. The work done this year will allow facilities to apply for installation and operating permits, apply for requests for determinations, apply for abrasive blasting and open burning permits, submit required reports and compliance certifications and access ACHD reviews of submitted applications and reports.

Air quality complaints can be received through the online comment and complaint system  GovQA . Inspectors investigate complaints through an onsite inspection or administratively based on the complaint details. On average, complaints are resolved in under 10 days.

Data from GovQA can be analyzed to see trends residents may be experiencing across the county like where specific odors are found or if concerns center in a specific area. This helps the program to better understand needs of residents. Total Complaints – 1,003 Total complaint inspections – 736

In 2023 the Air Quality Program maintained monitored attainment for all criteria pollutants listed in the Clean Air Act.

Each criteria pollutant has its own National Ambient Air Quality Standards (NAAQS) that are updated as needed. For example, the PM _2.5  standard for 2023 is based on standards set in 2012, while the sulfur dioxide (SO ₂ ) standard was set in 2019 and ozone (O ₃ ) in 2015. If monitors are reading under those levels based on the three-year design value averages that pollutant is considered as reaching monitored attainment.

Additional RACT Requirements for Major Sources of Nitrogen Oxides and Volatile Organic Compounds

Effective January 1, 2023. This amendment updates Article XXI with the new national Reasonably Available Control Technologies (RACT) requirements and emissions limitations for owners and operators of certain major sources of nitrogen oxide (NO ₂ ) and volatile organic compounds (VOC).

Control of VOC Emissions From Unconventional and Conventional Oil and Natural Gas Sources

Effective February 5, 2023. This amendment to Article XXI is to incorporate a PA DEP regulation mandated by the EPA. State and local agencies need to create regulations for control technique guidelines, in this case for VOC emissions of oil and natural gas.

Municipal Solid Waste Landfills

Effective July 3, 2023. Landfills emit air pollutants as waste decomposes. The Clean Air Act requires the EPA to establish performance standards for municipal solid waste landfills. State or local agencies can request that they be delegated as the regulatory body for new and existing landfills. By submitting a plan to the EPA and updating Article XXI, the Air Quality Program now over sees air pollution regulation of landfills in Allegheny County.

• Special studies began for PM _2.5  source contributions and wildfire smoke impacts
• State Implementation Plans were finalized and sent to the EPA for Oil and Gas Control Technique Guideline Regulations and Sulfur Dioxide Redesignation Request and Maintenance Plan for the 2010 Standards
• Monitoring and emissions data submitted to the EPA showing continued monitored attainment of all criteria pollutants

Though Allegheny County has been meeting the PM _2.5  standards there is a possibility that will change. The EPA revised the annual PM _2.5  standard from 12.0 um/m ³  down to 9.0 um/m ³ . The 24-hour standard has not been changed. Allegheny County will have two years to provide data to the EPA before any designation on attainment status is made by the EPA, likely in 2026.

There will be little change to the  Air Quality Index  . The difference between what is considered "good" and "moderate" has narrowed and the ranges for "unhealthy", "very unhealthy", and "hazardous" have reduced. The new standard maintains the same threshold for  Mon Valley Air Pollution Episode  watches and warnings.

The ACHD tracks emissions data known as the “Emissions Inventory” from the largest permitted sources in Allegheny County. Emissions data is studied to understand what types of controls might be needed at local facilities and area/mobile sources in order to meet the National Ambient Air Quality Standards. The Health Department uses this inventory to better understand air quality trends and regulate pollution in the county.

 The dashboard  provides easy access to emissions data collected over the last 10+ years. It allows everyone to better visualize and understand the distribution of point source pollution across the county. The dashboard shows significant decline in emissions over the past 10+ years.

The  Clean Air Fund  disperses funds received from all penalties, fines and interest received under Article XXI. This money is used to support activities related to the improvement of air quality within Allegheny County and activities which will increase or improve knowledge concerning air pollution. In 2023 the clean air fund granted over $2.3 million for clean air projects.

2023 Projects - $2.3 million Steel Rivers Council of Governments - $750,000 Replacement of a diesel street sweeper with an electric street sweeper

Borough of Swissvale - $700,000 Replacement of two diesel recycling and refuse trucks with electric recycling and refuse trucks

Borough of West Mifflin - $748,339 Replacement of a diesel refuse truck with an electric refuse truck

Tree Pittsburgh – Two grants for $46,000 each Education and tree plantings in the Steel Valley and Woodland Hills School Districts

Support for Carnegie Science Center Future City Competition, $9,000

Support for Pittsburgh Regional Science and Engineering Fair, $15,000

There are many ways to stay updated on air quality in Allegheny County, what the Air Quality Program is doing, and to connect with the program. Take a look at dashboards, data sets, share your thoughts through public comment and the GovQA comment/complaint portal, attend meetings, and sign up for alerts.

Below are live air quality tracking resources including the NAAQS dashboard, hydrogen sulfide dashboard, hourly air quality data, daily dispersion report, and the PA DEP daily air quality forecast.

This dashboard is updated hourly, every day of the year for fine particulate matter (PM _2.5 ), sulfur dioxide (SO ₂ ), and ozone (O ₃ ). The dashboard is interactive by location, pollutant, and time period.

 Hydrogen sulfide  (H ₂ S) is a colorless gas with a rotten egg-like smell. The most common sources of H ₂ S are from industrial processes like oil and natural gas refineries, craft paper production, coke ovens and tanneries. These activities form H ₂ S by combining high heat, sulfur and organic matter. H ₂ S is also released at sewage treatment facilities, landfills, as well as during bacterial breakdown of human and animal waste.  There is no national standard for ambient air H ₂ S. Pennsylvania is one of a few states with ambient air H ₂ S regulations, the 24-hour standard for H ₂ S is 0.005 ppm and the one-hour standard is 0.1 ppm. The commonwealth’s regulation is based only on the odor’s nuisance and not on a health standard.

For more than just the NAAQS and H ₂ S the Air Quality Program provides  a document of all pollutants tracked  at each monitoring location for the past seven days. Numbers are updated hourly as applicable.

The  Daily Dispersion Report  is updated each weekday on the county website. It shows what the highest anticipated Air Quality Index (AQI) for Pittsburgh and the Liberty-Clairton area for that day and the next as reported by the PA DEP. The report also includes a short description of daily meteorology and inversion information. To receive the report directly to your email,  subscribe to enviroflash .

Below are ways to communicate with the Air Quality Program. This includes subscribing to air quality alerts, public comment, and where to ask a question or file a complaint.

Sign up for Allegheny Alerts to always be up to date on Mon Valley Watches and Warnings, Air Quality Action Days and other important Air Quality news. You may opt to sign up for other county alerts as well. Alerts can be sent through text, email, phone call or any combination of the three. Alert options can be changed at any time.

To subscribe to Air Quality alert’s, create an account then click on “My subscriptions” ⮕“Allegheny County Health Department” ⮕“Air” and select alerts to be notified of.

This is the  online comment, complaint, and reporting platform  for Allegheny County. Complaints can be filed about odors, smoke, dust, open burning, asbestos, demolition and more.

 Air Advisory Committee  meetings are open to the public. People can join either in person or virtually and share thoughts during the public comment portion of the meeting.

 Board of Health  meetings are open to the public, to speak at the meeting people must sign up in advance and speak in person. Written comment may be submitted online. Speakers at Board of Health meetings are limited to three minutes. Anyone may attend in person or view meetings online.

Public comment periods are for a minimum of 30 days. All regulation changes, State Implementation Plans (SIP), Title V Permits, and Annual Monitoring Network Plans go to  public comment . Written comments can be submitted via email or mailed to the Air Quality Program. Toward the end of the public comment period (if someone has registered before the cut-off date) there is an in-person hearing for the public to testify. Testimony is limited to three minutes.

All comments, written or oral, are equally considered by the Department. The ACHD drafts a document with all public comments made on the regulation change/SIP/permit/monitoring plan along with the Department responses and makes any necessary adjustments before agency action is made on the regulation, permit issuance, SIP submittal, or monitoring plan.

In 2023 the Air Quality Program had the following public comment periods:

• Regulation: one regulation to public comment, one in-person hearing
• SIPs: one SIP to public comment, one in-person hearing
• Permits: 14 permits to public comment, eight in-person hearings
• Annual Monitoring Network Plan: one plan to public comment

The Air Quality program and its dedicated staff did a tremendous amount of work in 2023, yet there is still more to accomplish. Enforcement cases continue to be litigated, permits and reduction of overdue permits continue to be issued with expedience, data analysis and monitoring network improvements/expansions are ever advancing. The complicated work to meet the 2024 federal PM _2.5  standards has already begun. Before the new standard was announced the  Plan for A Healthier Allegheny  already identified the goal of reducing PM _2.5  by 12%, from 9.7um/m ³  in 2021 to 8.5 um/m ³  in 2027. This new standard will have to be met for the 2030-2032 three year design values.

This work is complex, never ending, and takes much longer than many people realize, but as seen by the long-term air quality trends in Allegheny County the effort certainly yields tangible and positive results.