Muller’s list of problematic Delaware sites from Governor Markell’s “transition” process

I had a small involvement in the DNREC “subcommittee” of Markell’s transition team.  For the most part, this was controlled by Guy Marcozzi, President of Duffield Associates, one of Delaware’s most aggressive developers’ consulting firms.  The nominal head of the subcommittee was Debbie Heaton of the Sierra Club and The Nature Conservancy.  Heaton openly connived with Marcozzi to diss environmental concerns.

The transition reports rightfully should have been public documents and I pushed a bit for them to be posted.  As far as I know they never have been; not surprising considering the secretive tendencies Markell’s administration has shown since the election.

In any case, the document  below was contributed by me.  I don’t know if it was included in the final report.

(email to DNREC transition team subcommittee)

Jan 11, 2009

This is a partial list of 23 major sites or categories of sites, posing–in Muller’s opinion–substantial health, environmental, and financial concerns.  The concerns may involve any or all media (air, water, land….).  They all pose, in my perception, more than a purely local impact and have the potential to “bite” the new administration.

There is no particular order or priority except for a general North to South progression.

(I am sure the list is far from complete but I received no input from other members of the DNREC subcommittee.)

(1) Sunoco oil refinery
Mostly in PA but partly in Delaware;
Community concern over sulfur compound releases;
Questions remain over a cooling water intake.

(2) Claymont Steel
Extensive community concern with continuing discharges of dust and mercury;
A independent air/dust sampling program is yielding results suggesting ongoing health hazards;
Site owners are presently uncooperative in the face of substantial DNREC prodding;
Closure possible and site is likely highly contaminated;
NPDES permit is expired.

(3) DuPont Edge Moor Plant
permitted and un permitted (the “Dioxin Pile”) dump sites are contaminated with dioxins, radioactives, & etc.;
There is an ongoing controversy over community demands for removal of the “Dioxin Pile;”
DuPont has threatened and bullied community leaders;
History as the largest US dioxin source;
Recently, NPDES permit was changed after a no-record “public hearing;”
Poses safety hazard due to presence of large amounts of chlorine;
Unregulated but dangerous wastes being sent to a dump in South Carolina without community notice;
Contaminated waste products from this plant have been used to treat drinking water and wastewater–including

(4) Conectiv Edge Moor Power Plant
Coal, oil, gas, and landfill fume powered generating station;
Conectiv has aggressively disputed the DNREC “multi-pollutant” regulation;
Open circuit cooling systems are impacting aquatic populations;
Irresponsible management of coal ash (12th St., Pigeon Point….);
Such coal power plants are candidates for phase-out due to health and climate change impacts;
NPDES permit is expired.

(5) Wilmington Combined Sewer System
About 40 “CSOs” discharging untreated into Christina River, Brandywine Creek, and Delaware River;
There is a dishonorable effort going on to, in effect, weaken the water quality standards applying;
Wilmington, DNREC, EPA have all collaborated to avoid fixing the problem;
An obvious “infrastructure” investment project;
NPDES permit is expired.

(6) Wilmington sewer plant
A history of permit violations;
Treatment steps are bypassed during rainstorms/snow melt;
High emissions of toxic air pollutants aren’t reported under the TRI;
Serves most of New Castle County–Wilmington runs it as a business.
See CSO’s as a separate item but they are under the same NPDES permit–which is expired

(7) Many Wilmington–and elsewhere–“Brownfield” sites …..
Wilmington was one of the first few places in the US to be heavily industrialized;
Groundwater issues are not adequately addressed because sites are addressed “piecemeal;”
Soil remediation standards, especially for Arsenic, are not health-based nor adopted in a transparent manner;
Sites aren’t getting adequate cleanup.

Note: I believe the DNREC Site Investigation and Restoration Branch (SIRB) has a list of about 600 “brownfields” in Delaware, defined as “industrial or commercial properties which have been abandoned or under utilized as a result               of hazardous substance contamination.”

(8) Cherry Island garbage dump (DSWA)
History of odor problems/high gas emissions;
Complaints from New Jersey;
Impacts “environmental justice” communities in East Wilmington;
Dump is unlined … wastes are essentially uncontained;
An expansion costing +/- $100,000,000 was approved by DNREC over strong community opposition;
DSWA “accepted” permit conditions related to a “yard waste” ban but did not keep its word.

(9) 12th Street sludge/coal ash site
Large amounts of coal ash, incinerator ash, etc have been accumulated by VFL, Wilmington’s sludge disposal contractor, which is seeking to abandon the materials in place;
These activities are tied to the improper reopening of the Pigeon Point dump site;
One of Delaware’s most inexcusable environmental debacles.

(10) AMTRAK Wilmington shops
Long-time locomotive heavy repair facility highly contaminated with PCBs–may be discharging into Delaware River.

(11) Hercules Golf Course/Experimental Station
Heavily contaminated site(s) moving towards residential development in face of community opposition;
The “poster child” for the problems with the “agricultural” exemption from the HSCA site cleanup law and DNREC jurisdiction.

Note: Golf courses tend to be highly contaminated because of extensive chemical application.  Many date from times when lead, arsenic, mercury, DDT, and other persistent toxins were commonly used.  Any future state acquisition of old golf courses should consider this.  For similar reasons, conversion to residential use is questionable.

(12) Pigeon Point garbage dump (DSWA)
Supposedly closed but actually open for dumping of Wilmington sewage sludge/Conectiv coal ash, etc.;
Is unlined, has been a candidate Superfund site.

(13) Metachem/Standard Chlorine (Delaware City)
Owners declared bankruptcy and abandoned site on a few hours notice, leaving dozens of tanks, more than fifty rail cars, millions of pounds of chemicals and wastes….;
Superfund site with major groundwater contamination and other issues;
Groundwater contamination may eventually threaten Delaware City wellfields and other public water supplies;
State share of cleanup costs is substantial and ongoing (plus $10,000,000?);
A real cleanup of groundwater and soil contamination may never be achieved under the current plans;
The situation resulted from decades of State disregard for a growing problem–perhaps DNREC’s greatest single debacle and the story is far from over.

(14) Llangollen/Delaware Sand & Gravel
Old chemical and garbage dump sites originated by New Castle County–borrow pits unwisely used as dumps;
Superfund sites officially but inadequately cleaned up;
Groundwater contamination plumes continue to threaten public water supplies;
Pollutants appeared in Artesian drinking water;
A real cleanup may require reopening of federal “Superfund” process.
Wilmington drinking water.

(15) Oxychem (Delaware City)
Long-time mercury cell chlor-alkali plant with history of high mercury air emissions; mercury cells no longer operating but the site is heavily contaminated with mercury.  Mercury discharges to Delaware river;
Poses safety hazard due to presence of large amounts of chlorine gas.
A cleanup is in progress but is likely inadequate to restore site and protect surroundings.

(16) Delaware City Refinery
Consumes a great proportion of DNREC technical and enforcement resources;
Releases, complaints, violations are ongoing and always will be while facility operates….;
A generally defiant attitude is characteristic of the industry and has been consistent through a sequence of owners;
Fluid coker is one of few in world and management of “coke” product is continuing problem;
Geometry of cooling water intake and discharge makes for huge fish kills–cooling towers are urgently needed;
Propane is stored not in pressure tanks but–literally–in a hole in the ground.  DNREC has identified high leakage rates;
Evaded participation in RGGI, leading to large revenue losses & Etc.  this decision needs review;
Dredging issues….;
NPDES permit allows discharge of 38,000 pound per day of “oil and grease.”  Permit is expired.

(17) Formosa Plastics
Emissions of vinyl chloride monomer, an aggressive human carcinogen, are reduced but ongoing;
NPDES permit is expired.

(18) Salem I and II, Hope Creek I nuclear reactors
Located in New Jersey but majority of nearby population is in Delaware;
These are among the most historically troubled reactors in North America;
Likely public health hazard–breast and thyroid cancer, Etc. from normal operations;
Spent fuel–highly radioactive wastes–has accumulated since plant start up;
Open circuit cooling systems (Salem I and II) have large impact on fish populations.  Cooling towers are urgently needed;
DNREC has been supporting continued operation of open circuit cooling systems in return for about $2,000,000/year; in “estuary enhancement” contributions.  This is probably not environmentally or ethically defensible;
Evacuation planning is under purview of Div. of Emergency Management.  DEMA activities funded and highly coopted by plant owners;
Status of radiation monitoring is unclear and probably unsatisfactory;
There is some level of interest in siting a fourth reactor at the complex.  Unlikely due to excessive cost and strong public opposition, but big potential for controversy.

(19) Reichold Chemical (Dover)
Closing announced but long history of spills and releases suggests site is highly contaminated;
Uses large amounts of carcinogens.

(20) DuPont/Koch (Invista) Seaford Nylon Plant
Last remaining large coal-fired industrial powerhouse in Delaware.  Scheduled for conversion;
Air emissions; groundwater contamination from poor coal ash management;
Groundwater contamination from land application of wastewater treatment sludges;
Koch is sueing DuPont, alleging failure to disclose environmental problems;
Employment is much reduced, facility may be likely to shut down.

(21) Indian River power plant (NRG energy)
Groundwater contamination;
High air emissions–scheduled for reduction under “Multi-pollutant” regulation;
Associated with a “cancer cluster;”
Open circuit cooling system impacting Rehoboth Bay;
NPDES permit expired for 16 years, more than 30 outfalls….;
Many coal-ash related issues;
High climate impact from carbon dioxide emissions calls for phase out;
High level of community concern (Citizens for Clean Power).

(22) Waste water management for rapidly growing Eastern Sussex communities.
This is a general problem.  In my opinion the guidance provided by the DNREC has been vague, legalistic, and basically unsound, being focused on what can be permitted rather than what would actually solve the problems in a sustainable manner.

(23) Nutrient discharges from the poultry industry….
A widespread problem with many aspects and players;
Industry practices are unsustainable;
Nutrient Management Commission is industry-controlled and in confrontation with EPA;
It’s important that the incoming administration educate itself on this issue.

(24) The Delaware River/Bay (Estuary)
Dredging (“main channel deepening” ) scheme never seems to go away;
DuPont is dumping 3 million pounds per year of “TRI” toxins into Delaware waters from Chambers Works;
Need to revive coastal/ocean protection bill;
Need better enforcement/strengthening of Coastal Zone Act;
Controversies with New Jersey are likely over ports, riverboat gambling, LNG terminal, Etc.;
Need water quality improvements and restoration of fisheries–fish, oysters, crabs;
Fish throughout Delaware are generally unhealthy to eat.

And so on……

Regards,

am

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