Dust from a coal explosion once kept Michael McCawley from seeing his hand for more than five seconds during research for a 2014 study.
McCawley had been standing beyond a mountaintop mine on the side of a mountain near Naoma, in Raleigh County, where a resident lived.
The study found that particle matter concentration was significantly greater around mining areas than non-mining areas, indicating elevated risks to human health.
Roughly a decade later, McCawley’s outlook is still dark when it comes to particulate matter — solid particles and liquid droplets in the air that include soot and dirt. Much of the most harmful particulate matter, known as PM, follows combustion. Power plants and other industrial facilities, automobiles and fires are common culprits.
Darkening McCawley’s outlook now is the U.S. Environmental Protection Agency’s recently released plans to update — and not update — its air quality standards for PM, which studies have linked to heart attacks, aggravated asthma and premature deaths.
“I think they’re not protecting the public,” McCawley said.
McCawley said he believes air quality standards based on EPA PM concentration criteria are off-base because they fail to account for PM deposition in lungs.
The EPA’s new proposal for PM air quality standard updates released last month doesn’t include any outdoor air standards for ultrafine particles — those less than a tenth of a micrometer in diameter — despite evidence ultrafine particles threaten human health more than larger particles.
Researchers have found that ultrafine particles stay in the lungs longer than larger particles, and can move from the lungs to the neurological and cardiovascular systems. Ultrafine particles most often come from road traffic and industrial emissions.
McCawley said he believes the consequences for getting air quality standards wrong could be especially great in West Virginia, where studies have found substantially higher mortality and cancer rates around mountaintop mining areas versus non-mountaintop mining areas.
“This is probably going to come down hardest, first of all, on the people of West Virginia,” McCawley said of the EPA’s proposed renewal of its indicators for PM.
McCawley was talking about places like Eunice, a tiny, unincorporated Raleigh County community where residents have lived with coal dust accumulation in their homes from a nearby mine controlled by Alpha Metallurgical Resources.
Willie Dodson has overseen community dust monitoring in Eunice as Central Appalachia field coordinator for the environmental nonprofit Appalachian Voices. Dodson said he is disappointed in the EPA”s proposed rule.
“I had hoped for more,” Dodson said in an email.
So did the American Lung Association, which is calling for more stringent standards the organization says would save thousands more lives.
“[The] proposal from EPA to update the national annual limits on particulate matter pollution misses the mark and is inadequate to protect public health from this deadly pollutant,” American Lung Association president and CEO Harold Wimmer said in a statement last month.
In 2021, the World Health Organization recommended an annual air quality guideline of 5 micrograms per cubic meter for PM2.5, fine inhalable particles with diameters generally 2.5 micrometers and smaller — sometimes called soot.
For comparison, a human red blood cell is 5 micrometers.
The EPA has proposed strengthening the primary PM2.5 standard from the current 12 micrograms per cubic meter to between 9 and 10 micrograms per cubic meter.
The EPA’s proposal wouldn’t change the primary standard for PM10, which includes particles with diameters generally less than 10 micrometers, from its current standard of 150 micrograms per cubic meter.
The WHO has recommended a standard of 45 micrograms per cubic meter for PM10.
“It’s always an uphill battle to win policy that holds polluters accountable and prioritizes public health,” Dodson said.
The EPA last changed its PM2.5 primary annual standard in 2012. The agency says strengthening the standard to 9 micrograms per cubic meter would prevent up to 4,200 premature deaths and 270,000 lost workdays per year, with as much as $43 billion in net health benefits in 2032.
The WHO estimated PM2.5 exposure caused 4.2 million premature deaths worldwide in 2019. Over a third of those deaths were due to heart disease and stroke, and nearly a quarter were due to acute lower respiratory infections, per WHO estimates.
More than 143,000 lives would have been saved over a decade had the United States lowered its PM2.5 standard to 10 micrograms per cubic meter, a report by the Health Effects Institute released last year found. The nonprofit Health Effects Institute usually receives balanced funding from the EPA and the worldwide motor vehicle industry.
The EPA’s current 24-hour PM2.5 standard was issued in 2006. That standard is designed to protect against short-term exposures, especially where there are high peak PM2.5 concentrations. The standard is 35 micrograms per cubic meter of air, well above the WHO’s recommendation of 15 micrograms per cubic meter of air.
An area meets the 24-hour standard if the 98th percentile of 24-hour PM2.5 concentrations in one year, averaged over three years, is at or under 35 micrograms per cubic meter of air.
Only 14 counties in California and Allegheny County in Pennsylvania were considered PM2.5 nonattainment areas as of Jan. 31, according to EPA data.
But local air quality monitoring data is scarce in West Virginia and throughout the country.
“Even the strongest ambient air quality standard is only as good as the data it relies upon,” Dodson said.
The West Virginia Department of Environmental Protection’s air monitoring network only monitors for PM2.5 pollutants across 13 sites in just 11 of West Virginia’s 55 counties. None of those sites are located in the state’s southern coalfield counties.
Seventeen Eunice residents signed a petition submitted by Dodson to the DEP earlier this year urging the Division of Air Quality to examine the impacts of fugitive mine dust on ambient air quality by placing pollution monitoring devices in Eunice and in other communities facing similar problems.
The DEP rejected the request.
“[T]he DEP does not do their job right,” Shelia Walk said in an interview last year after resolving to move away from Eunice, exasperated over what she said was mine dust infiltration in and around her home. “If they did, we wouldn’t be moving.”
The EPA is taking comment on the proposal, with virtual public hearings slated for later this month.
“I can’t express enough gratitude for all the ordinary Americans who are fed up with breathing bad air, and whose advocacy has made this an issue that EPA is compelled to address in the first place,” Dodson said.
A 2014 study that researchers from the Centers for Disease Control and Prevention and Indiana University coauthored with McCawley concluded measuring the fraction of PM deposited in the lung is technically feasible for different PM size distributions.
The fraction of PM depositing in the lung is a “more sensitive indicator” of epidemiological disease patterns than PM10 or PM2.5, the study published in the peer-reviewed Journal of Exposure Science and Environmental Epidemiology concluded.
The study determined particle size distributions with two near-real-time instruments for two particle size ranges, including an aerodynamic particle sizer that measured size-classified mass concentrations for size categories based on the aerodynamic diameter of certain particles.
PM respiratory deposits were calculated with a mathematical model based on International Commission on Radiation Protection standards, the study said.
“You’d have to change all the hardware that’s out there,” McCawley said of what a better PM deposition measurement method would require.
EPA spokeswoman Shayla Powell noted that PM2.5 and PM10 indicate exposure, not lung deposition. Powell said the selection of PM2.5 as an indicator in ambient air quality standards in 1997 stemmed from epidemiologic studies of large populations showing a relationship between PM2.5 exposure and health effects.
WHO air quality guidelines published in 2021 include integrating ultrafine particle monitoring into existing air quality monitoring, with measurements at selected air monitoring stations. The WHO recommended using emerging science and technology to better assess ultrafine particle exposure.
In response, Powell cited a May 2022 EPA policy assessment finding that evidence for health effects following exposures to ultrafine PM is more limited than PM2.5-related evidence. That assessment said evidence for fine particle health effects didn’t support consideration of other PM characteristics like size fractions.
“A thorough discussion is called for, it just won’t be done by the EPA,” McCawley said.
Air quality advocates want a more thorough network of air quality monitors.
Over 82% of the nearly 3,000 counties nationwide with PM2.5 estimates modeled under 8 micrograms per cubic meter have no PM2.5 air monitor, according to an analysis released last month by the National Resources Defense Council, an environmental nonprofit. More than 107 million people live in counties without at least one PM2.5 air monitor, per the analysis.
A November 2020 federal Government Accountability Office report found the EPA had failed to take a “strategic and nationally consistent approach” to managing the nation’s ambient air quality network.
The report cited a National Association of Clean Air Agencies estimate that state and local governments fund three-quarters of their overall air quality management programs, including air monitoring networks.
The Government Accountability Office, a federal watchdog agency, found the nation’s air quality monitoring system couldn’t meet needs for information on air pollution hotspots, short-term air quality changes in real time or air quality in rural areas.
In its response to last year’s petition signed by Eunice residents, the DEP said its PM monitors are sited near higher population areas to capture ambient air where more people live.
The DEP has one PM monitor location each in Berkeley, Cabell, Hancock, Harrison, Marion, Marshall, Monongalia, Ohio and Wood counties, and two each in Brooke and Kanawha counties, according to its 2022 Ambient Air Monitoring Annual Network Plan.
“Air quality in cities and bigger towns is an important priority, for sure. But it doesn’t justify totally ignoring rural areas,” Dodson said.
Searching for stronger standards
As concerns linger over the EPA’s air quality monitoring methodology and availability in West Virginia, state lawmakers are focused on making life easier for the West Virginia coal industry responsible for high emissions of pollutants that drive up PM levels.
Reported greenhouse gas emissions from large industrial sources in West Virginia increased by 13% from 2020 to 2021, according to EPA data released last year. Those greenhouse gases include sulfur dioxide and nitrogen oxides, which form particles contributing to PM.
West Virginia coal-fired electric power plants in 2021 emitted over 86,000 tons of sulfur dioxide and nitrogen oxides, according to federal Energy Information Administration data.
In a four-hour stretch Thursday, West Virginia lawmakers advanced tax relief measures designed for coal companies estimated to cost the state over $90 million per year and save one of the state’s largest polluting plants from shuttering.
The Senate Energy, Industry and Mining Committee approved Senate Bill 168, which would exempt steam coal sold to in-state power plants from coal severance tax at a Department of Revenue-estimated annual cost of $22 million.
The House Technology and Infrastructure Committee approved House Bill 3133, which would allow coal companies to use tax credits against their severance tax liability to encourage them to make road and other infrastructure improvements at a Department of Revenue-estimated annual cost of $70 million.
The House Energy and Manufacturing Committee approved a resolution encouraging Mon Power to buy the coal-fired Pleasants Power Station, a plant slated to close this spring that the Legislature already bailed out with $12.5 million in annual tax breaks in 2019.
Electric power producer Energy Harbor said it’s deactivating the plant to aid its transition to carbon-free energy.
Emissions from the Pleasants plant resulted in an estimated 64 deaths, 25 heart attacks, 642 asthma attacks and 3,199 work-loss days in 2019, according to an analysis of data from a federal health risk assessment tool derived by the Clean Air Task Force, an environmental group.
“It is no secret that coal and other polluting industries have enormous sway over politics and government in [West Virginia],” Dodson said. “This is why we need strong action at the federal level. With this proposed rule, EPA has failed to provide that necessary action.”
Time for input
The EPA is taking comment on its rule proposal until March 28. The agency said it would take input on alternative annual PM2.5 standard levels between 8 and 11 micrograms per cubic meter of air and revising the 24-hour PM2.5 standard as low as 25 micrograms per cubic meter of air.
Comments may also be mailed to U.S. Environmental Protection Agency, EPA Docket Center, Air and Radiation Docket, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
Dodson said he is confident there’ll be a robust response from public health advocates on what he believes is a disappointingly small step in the right direction.
“The American public has been paying to be protected,” McCawley said. “They should get the protection they’ve paid for.”
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