Joint Comments from LU and LC on Draft Operating Permit for McConway and Torley

Joint Comments from Lawrenceville United and Lawrenceville Corporation

Regarding Draft Operating Permit for McConway and Torley

On behalf of Lawrenceville United and Lawrenceville Corporation, thank you for the opportunity to provide comments to the draft operating permit for McConway and Torley. Lawrenceville United’s (LU) mission is to improve and protect the quality of life for all Lawrenceville residents. Lawrenceville Corporation (LC) serves as the catalyst and conduit for responsible growth and reinvestment in the Lawrenceville community.

Since around the time of Allegheny County Health Department’s 2015 draft operating permit for McConway and Torley, LU and LC have organized a number of community meetings related to the steel foundry and the air quality permit process. We thank the Health Department for working with us to provide presentations to the community about the details of this draft operating permit. Special thanks is owed to David Good and JoAnn Truchan for making time to come out to multiple community meetings.

Based on the feedback we’ve received from residents and stakeholders throughout this community process, LU and LC respectfully request the following from the Health Department:

  1. Fence-line monitoring should continue and be a requirement of the final operating permit. Residents have every right to be concerned about emissions of toxic metals into a dense residential neighborhood, based on the documented health risks associated with these pollutants. Over the course of the fence-line monitoring timeline, the general trend of the monitored results has been a decrease in the average concentrations, which is reassuring. However, of stationary air pollution sources in Allegheny County, McConway and Torley was still the 5th largest source of manganese emissions in 2016, and the 8th largest source of chromium emissions, according to the DEP. Furthermore, the monitor continues to show spikes in manganese levels on certain days well above the 12-month average. The monitor also showed a significant and sustained year-long increase in chromium levels between March 2016 and April 2017, more than tripling the 12-month average. It doesn’t appear that analysis has been done by the Health Department on the potential causes of this variability, or on comparing spikes in emissions to production levels at McConway and Torley. Additionally, residents have expressed concerns about the monitor’s location with respect to prevailing winds, as well as questions about how representative the monitor’s results are, since it only runs 1/3 of the time and on a regular schedule that can be easily anticipated. In the interest of protecting the health of residents and providing transparency to the community, the Health Department should at minimum require the continuation of the fence-line monitor as part of the operating permit for McConway and Torley until these questions can be adequately answered by the Health Department.
  2. Emissions testing in the operating permit should be more frequent than every five years. Again, given the foundry’s location within a dense residential community and the known health risks of the pollutants involved, it is entirely reasonable for the Lawrenceville community to want timely and transparent access to reliable emissions testing results. Requiring emissions testing only every five years is too infrequent for the community to have confidence that the terms of the operating permit are being met. The Health Department should require emissions testing on a more frequent basis as part of the operating permit.
  3. Odor complaints need to be addressed. While the draft operating permit prohibits McConway and Torley from emitting malodors beyond its property line, we are concerned about the Health Department’s history of enforcing this. According to data from the Smell Pittsburgh app, 15201 had the 7th highest number of smell complaints out of 85 zip codes last year – 316 total complaints. 58 of those complaints specifically mention McConway and Torley, and the vast majority (86%) of those complaints were marked “definitely noticeable”, “it’s getting pretty bad”, or “about as bad as it gets.” 91 additional smell complaints noted an “industrial” smell or specifically mentioned “foundry.” LU has received reports from nearby residents noting that in addition to the smell, residents have experienced a bad taste from the air and stinging/watering of the eyes. Despite the quantity and intensity of these complaints, the Health Department reports that no notices of violation have been issued to McConway and Torley regarding odors, and it appears that no analysis has been done to compare odor complaints to the foundry’s production levels. Consequently, LU and LC implore the Health Department to mandate better odor control technology as part of this permit, or else to better investigate and enforce the complaints it receives; otherwise, the site level condition around odor emissions is meaningless.
  4. More communication and study is needed by the Health Department on the potential health effects of air pollutants to Lawrenceville residents. We know that Allegheny County is home to some of the worst air quality in the nation, that poor air quality creates significant health risks (particularly for more vulnerable populations), and that industrial sources are one of the largest contributors to local particle pollution in the County. Residents have reasonably asked the Health Department for more information and analysis on incident rates within the Lawrenceville neighborhood of health risks associated with the pollutants that McConway and Torley emits. Despite these requests, no communication from the Health Department’s epidemiology team has been received, and the Health Department declined Lawrenceville United’s request to extend the public comment period to provide time for residents to hear from a medical expert at the Health Department and have their questions answered. The Health Department should not have this disconnect between its air quality permitting and epidemiology programs. The potential health effects of air pollutant emissions should be central to the permitting process. Residents want to understand how the Health Department not only applies federal regulatory standards through its air quality permits, but is actively working to improve the air quality of the County. Lawrenceville is home to over 10,000 residents, including significant populations of older adults, children, and individuals from low socioeconomic backgrounds, who are placed at greater risk by pollutants and poor air quality. The community deserves further study by the Health Department to understand how Lawrenceville residents—particularly the most vulnerable—may be affected by air quality. Cancer rates among adults in Central Lawrenceville exceed city averages by considerable margins, and residents have asked for further inquiry.

In closing, we ask that these requests be reflected in the final operating permit for McConway and Torley. We believe that these requests not only protect the health and quality of life of Lawrenceville residents, but would also serve to strengthen the ongoing relationship between McConway and Torley and the residential neighborhood.

Thank you for your consideration and for the Health Department’s engagement throughout this process. We look forward to receiving correspondence on these matters.

 

Sincerely,

 

David Breingan                                                           Matt Galluzzo

Executive Director                                                      Executive Director

Lawrenceville United                                                 Lawrenceville Corporation

118 52nd Street, Suite 2026                                       100 43rd Street, Suite 106

Pittsburgh, PA 15201                                                  Pittsburgh, PA 15201

(412) 802-7220                                                           (412) 621-1616

Dave@LUnited.org                                                     matthew@lawrencevillecorp.com

Notes from Community Meeting on McConway and Torley’s Draft Operating Permit

A new draft operating permit has been issued by the Allegheny County Health Department (ACHD) for McConway and Torley, a steel foundry in Central Lawrenceville. The public comment period began on Thursday, November 2nd, 2017 and ends on Monday, December 4th.

On November 16th, Lawrenceville United and Lawrenceville Corporation hosted a community meeting with ACHD to provide information on the specifics of the draft operating permit. Please see below for meeting notes and the presentations from ACHD and Lawrenceville United:

For a quick 1-page summary of the draft operating permit and the community meeting, please also check out this summary document that LU compiled with key information.

For additional information about the air quality permit and the public process, please see below:

How can the community have a voice in this process? ACHD is currently accepting comments from the public through December 4, 2017 in one of the following ways

  1. Speak at the public hearing on Monday 12/4 at 6 p.m. at Arsenal Middle School (220 40th Street). Must register with Karen Sagel at 412-578-8115 no later than 4 p.m. on Friday, 12/1.
  2. Email to aqpermits@alleghenycounty.us
  3. Mail to 301 39th Street, Pittsburgh, PA 15201

If you want help preparing your testimony/comments, PennEnvironment has offered to be a resource. Contact Zach Barber at 412-521-0943 or zach@pennenvironment.org.

Lawrenceville United also encourages residents to reach out to us with comments or questions at 412-802-7220 or info@LUnited.org.

Recap from Health Dept. presentation on the air quality permit process

In advance of Allegheny County Health Department’s upcoming release of the draft operating permit for McConway and Torley, Lawrenceville United and Lawrenceville Corporation hosted a community meeting with ACHD on 10/4/2017 regarding the air quality permit process, what to look for, and how the public can engage.

Please see below for materials from the meeting:

    • Powerpoint from ACHD
    • Full video of the presentation and Q&A:

According to ACHD, the draft operating permit for McConway and Torley will be released at the end of October or at the beginning of November. A minimum 30-day public comment period will ensue, during which community members can provide input on the draft operating permit.

LU and LC will schedule a community meeting with ACHD specific to the McConway and Torley operating draft within that period, and are also working with ACHD around scheduling a public hearing in Lawrenceville.

For any questions, please contact LU at 412-802-7220 or info@LUnited.org.

Why air quality matters:

  • Current levels of pollution still place the City of Pittsburgh in the dirtiest 15% in the country for particulate matter 2.5 (PM 2.5)
  • Pittsburgh is the 8th most polluted city in America for PM 2.5, and the 26th most polluted city for ozone.
  • Air pollution is the 4th highest-ranking risk factor for death globally, and the 10th highest-ranking risk factor in the United States.
  • The health effects of air pollution include increased risks of cardiovascular disease, lung cancer, asthma & respiratory disease, reproductive and developmental outcomes.

Free mini-consultations with architects at “Housing For All” event

Got a home project in mind? Want a personal consultation with an architect or landscape architect? FREE 15-minute mini-consultations with architects from the Design Center are available from 12-2 PM this Saturday 8/12 at the Lawrenceville “Housing For All” Event & Workshop sponsored by Allegheny Valley Bank / Standard Bank. Sign up using the Google Form HERE and bring your photos/drawings/plans with you!

The Lawrenceville “Housing for All” Event & Workshop starts promptly at 12 noon on Saturday 8/12 at the Persad Center (5301 Butler Street, Suite 100) and will last until 4 PM with a full day of presentations, discussions, and resources related to housing for renters, homeowners, and prospective homebuyers. Free lunch, childcare, and LED lighbulb & nightlight giveaways from Duquesne Light. Topics include renters rights, affordable homeownership programs in Lawrenceville, a legal panel, weatherization programs, abating lead in your home, and much more. Please see flyer and schedule below for more information.

 

Update on Morgan’s Barbecue (proposed restaurant at 4501 Butler Street)

Please see below for some updates on plans for Morgan’s Barbecue, a proposed new restaurant at 4501 Butler Street.

  • Their Zoning Board of Adjustments hearing is Thursday, May 11th at 8:50 AM at 200 Ross Street in the 1st floor conference room.
  • For meeting minutes on the most recent community meeting on 5/1/17, please click here.
  • Morgan’s Barbecue’s most recent site plan, which has changed since the community meeting on 5/1/17 in response to comments that were raised there, is available here and below.
  • The revised list of variances/special exceptions they’re seeking from the Zoning Board of Adjustments is available here.
  • LU and LC worked with Morgan’s Barbecue on terms of a community agreement that addresses concerns raised by the community, specifically related to future expansion of the outdoor seating area, outdoor entertainment uses, hours of operation for the outdoor area and garage doors, smoke capture, noise mitigation, security, deliveries, and trash collection. To see the terms of that agreement, please click here.

For any questions or feedback, please contact Lawrenceville United at 412-802-7220.