Category Archives: air quality

Chicken waste plant Coastal Zone Permit–Green Delaware’s comments

In an earlier post we promised these comments last week.  Apologies for the delay.  The matter is complex for us because it involves not only the merits of the “Green Recovery Technologies” application itself, but the manner in which enforcement of the Coastal Zone Act has been largely rendered (notice pun) into a farce.

Our comments are in the record.  We concluded that

“Green Delaware does not oppose further processing of wastewater treatment sludge from poultry slaughtering operations. It is possible that such could be desirable.  But the GRT application has innumerable fatal defects. The DNREC should deny the requested CZA permit.” 

Continue reading

Can we stop another big stink? Can we get the Coastal Zone Act enforced?

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Is there any end to it …?

(Note:  We get that this might seem trivial compared to the giant oil and gas facilities being shoved into Delaware.  More upcoming on those.  But if we can’t enforce our environmental laws on smaller projects, how can we expect to enforce them on big ones?)

No permit (yet) but the poultry waste plant already built.  Who are they kidding?  (US)

Skids greased for polluters but public participation curtailed

Readers will know that Peninsula Composting has been ordered to shut down.  The facility is supposed to be clearing out its existing materials.  Neither Peninsula nor DNREC have been returning phone calls, so we can’t tell you a lot more.

We’ve worked up a description of how the situation developed and what went wrong.  There’s is plenty of blame to spread around.  This grew to three thousand words, so we decided not to email it.  Read it here:

Update on the Big Stink from Peninsula Compost (“Wilmington Organics Recycling Center”)

Treating people worse than garbage in Delaware?

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Comments IN RE Draft Amendments to Regulation 1124 Section 36.0 “Stage II Vapor Recovery”

Mr. Robert Haynes, Hearing Officer
Delaware DNREC
Green Delaware’s Comments IN RE Draft Amendments to Regulation 1124 Section 36.0 “Stage II Vapor Recovery”

Dear Mr. Haynes:

Green Delaware recently began a review of the record in this matter. (We had not been invited to participate in the “review committee” and were not contacted by other “environmental” participants.) We appreciate the extension of the public comment period as we requested and hope you find our comments useful.

A considerable amount of technical documentation has been generated by the Department and in general we feel the work is competently done and does not need repetition here. This is in addition to an extensive existing literature of EPA reports, industry publications, etc.

Handling gasoline exposes people to various toxins such as benzene–a known cause of cancer in humans. Therefore, minimizing these exposures, and resulting health impacts, should be considered a priority in addition to the concern of VOC contributions to ozone formation. The gas station people, at least in their public hearing testimony, did not address health impacts to their employees and customers.

The Division of Air Quality is proposing to do more to control gasoline vapor emissions than the minimum federal (USEPA) requirement, but less than the State of California, the leader in this area, is doing. Green Delaware feels that the DNREC proposal is sound and well-justified as far as it goes. But it does no go far enough.

The DNREC is proposing to allow the shutdown of Stage II vapor control at Delaware’s approximately 330 gas stations. This means that Delaware would rely on the On-board Refueling Vapor Recovery (ORVR) systems that most–but by no means all–cars and light trucks are now equipped with. This also means that off road equipment, motorcycles, boats, “gas cans” for lawn care equipment, generators, etc, would lose the vapor control now provided by gas station nozzles.

There exists an “incompatibility” between some forms of “Stage II” gas station vapor recovery equipment and the “on board” (ORVR) systems that can potentially cause increased emissions from the gas station systems. This incompatibility can be cured by modifications to the Stage II systems.

California long ago decided to keep Stage II systems in service and cure the “incompatibilities.” This approach provides the best control of gasoline vapors, and thus the maximum protection of air quality and public health. The equipment to do this is commercially available and demonstrated.

DNREC has shown that the present Stage II systems need more frequent inspection and maintenance. (“… a survey conducted during the development of the proposed regulatory revision indicated a majority of gas stations needed maintenance in order to pass the annual tank tightness test.”) Apparently, 70 percent of gas station systems initially fail to pass their annual leak tests. These leaking systems likely cause some occupational exposures, and customer exposures, as well as increased gasoline vapor emissions. So, the DNREC proposal for a continuous pressure monitor (CPM) requirement makes sense whether Stage II is retained or only a pressure monitoring system is required.

The comments and testimony of the gas station interests provided no real response to these concerns. Their objections seem to have little if any factual basis.

The EPA and other sources claim a very high degree of reliability and effectiveness for the on-board (ORVR) systems. Based on personal observation, we have some doubts as to the effectiveness of the nozzle/filler neck seal on many ORVR systems. (Without positive pressure in the tank, from an effective seal, the displaced vapor will not enter the on-board canister.) In our experience, visible vapor and gasoline odors are common at stations without Stage II controls. Further, it seems surprising that on board systems would have a very high degree of reliability when gas station systems have a 70 percent annual (de facto) failure rate. This causes us to suspect that the “break even point,” the point at which vacuum-assist Stage II systems are argued to increase, not decrease overall emissions, is probably farther in the future than the 2018-2019 time frame identified by the Division of Air Quality, if it exists at all. This further suggests that shutdown of Stage II systems in Delaware would be premature. Certainly shutdown of existing systems should not occur before the break even point.

The gas station people argue that the pressure in their tanks is likely to remain negative due to the dispensing of liquid from the pumps and the non-return of vapor. This may be, or might be if liquid withdrawal was constant, but if the systems are not vapor tight one may expect ingress of air and resulting vapor expansion. And their systems apparently do not reliably remain vapor tight. So, again, the continuous pressure monitoring is needed.

Therefore, sound public policy is to retain and modify Stage II vapor recovery, as necessary, to make it compatible with ORVR. An inferior alternative, the one now proposed by the Department, would allow the shutdown of Stage II vapor recovery but enact a continuous pressure monitoring requirement. The least desirable alternative would be the one apparently desired by the industry: Simple shutdown of State II.

Delaware usually tries to do a little better in air quality management than the minimum of federal requirements and the desirability of doing so in this case seems well-established. We urge the DNREC to “do the right thing.”

Respectfully submitted,

Alan Muller
Alan Muller, Executive Director
Green Delaware
Box 69
Port Penn, DE 19731 USA
302.834.3466
cell 302.299.6783
greendel@dca.net
www.greendel.org

Update on the Big Stink from Peninsula Compost (“Wilmington Organics Recycing Center”)

Treating the people like garbage in Delaware?

Our previous comments on this matter may have had some effect, but we don’t know what the Markell administration intends to do, and Department of Natural Resources and Environmental Control (DNREC) secretary David Small did not return a call (We didn’t really expect him to, because we know him, but we tried.).

We’ve had some long conversations with people in the industry, and studied the transcript of the public hearing, and talked with people in various parts of Delaware’s environmental regulatory agency (DNREC).  We draw on our 20 years experience with environmental controversy in Delaware. Continue reading

Green Delaware’s comments on Peninsula Composting

Green Delaware
Alan Muller, Executive Director
Box 69. One Stewart Street
Port Penn, DE 19731 USA
cell 302.299.6783
greendel@dca.net
www.greendel.org

September 10, 2014

Mr, Robert Haynes, Hearing Officer
Delaware Department of Natural Resources and Environmental Control
via email

Regarding:  Peninsula Composting–Renewal, or not, of “Beneficial Use Determination”

Dear Mr. Haynes:

Green Delaware recommends, reluctantly, that the Beneficial Use Determination and other approvals for Peninsula Composting (sometimes known as the Wilmington Organics Recycling Center, WORC) not be renewed, and that the facility be required to close. Continue reading

Peninsula Composting and composting in general

[Note:  This post is a work in progress because we are waiting for the DNREC to provide transcripts and other requested documents.]

Composting is a good thing.  It’s the best way to handle the “organic” materials that make up around 30 percent of “municipal solid waste” (garbage).  “Compost” is very useful in farming and gardening.

But composting, like everything else, has to be done right.  It is essentially a controlled form or rotting.   Done wrong, it can stink, cause air and water pollution, drive neighbors out of their homes.

Backyard or neighborhood composting doesn’t usually cause problems.  Many communities compost yard waste–grass clippings, etc, and this doesn’t usually cause problems.

Composting food waste is manageable but does have more tendency to cause odors and attract rodents, especially if animal parts are involved.

When sewage sludge is added to the mix, things obviously become even more difficult.

Trying to compost mixed garbage is always a disaster.

Composting is regulated by the Delaware Department of Natural Resources and Environmental Control (DNREC).  There are approximately ___ permitted composting operations in Delaware.

Delaware had one big, bad experience with composting by the Delaware Solid Waste Authority (DSWA, Green Delaware has often called it the “Dirty Authority”) at Pigeon Point, just south of Wilmington.  In the 1980s the DSWA started up a large composting operation as part of an elaborate garbage processing operation including an incinerator.  The feed to the composting operation reportedly included 275 tons per day of partially separated garbage and 250 tons per day of City of Wilmington sewage sludge.  It was a disaster, stinking people out of their homes.  The compost was unusable as it contained toxic PCBs.

This operation, along with the rest of the processing operations, were eventually shut down after years of community complaints.

For some background on the Dirty Authority see this article from 1998:  “Misguided Delaware Solid Waste Authority Embarrasses State, Harms Communities, Doesn’t Recycle our Trash.”

Jump to 2007 and a proposal for a 700 ton per day composting in South Wilmington.  There was lots of cheerleading for this and, as is often the case, Green Delaware stood mostly alone in raising concerns.  Some of these:

o     It would be a large operation that would bring hundreds of tons per day of often-rotten food waste from surrounding states; a much larger operation than needed to meet Delaware needs.  Because of the distances, food waste would have a chance to get stinky before it even entered the composting process;

o     It would be located in a classic “environmental justice” (lower income, people of color) community already burdened by many health and environmental problems;

o     Some of those involved had a history of causing environmental problems.

See this 2007 Wilmington News Journal article: “Recycling company wants to compost out-of-state food waste near Wilmington

The Southbridge Civic Association signed a “Community Benefits Agreement” with the promoters.  We are waiting for a copy, but a description of it is available in this presentation.

Marvin Thomas, former President of the Southbridge Civic Association, said there were few complaints during the first couple of years of operations, but many since.  He said the Civic Association and surrounding communities are united in their desire that Peninsula Composting be shut down.  He indicated that communities have not recently sought to implement other parts of the agreement because they are at odds with Peninsula.  He also indicated that many community residents are not interested in working there because of poor working conditions and low pay.

Wednesday, August 27, 2014, is a bad air day in Delaware

All sorts of bad air on Wednesday, Aug 26th:

Delaware Department of Ag violating law to protect chicken scam?

 New York City garbage going to Chester, PA, via Elsmere, DE?

More power lines to be hung up over the Delaware River?

Utility ripoffs in general and in particular….

The DNREC has announced an “air quality action day,” saying that ozone is forecast to be in the Code Orange range and particles are forecast to be in the Code Yellow range.

The official forecasting system does not consider the combined effect of multiple pollutants, but Green Delaware does, and we say this is a Code Red (unhealthy for everybody) day. Continue reading

Tuesday: Breathe with care in Delaware …..(etc)

Bad Air

Tuesday August 5, 2014 is an official Code Orange “air quality action day” in Delaware.  The DNREC says: “A Code Orange air quality forecast for ozone is a level of pollution that can be unhealthy for sensitive groups, such as young children, the elderly, and those with heart and/or respiratory conditions. Such persons should limit outdoor activities, especially those that require a high level of exertion.”

Continue reading

Object to Censorship at “Delaware City Day”

Delaware City, whatever it’s other charms, has been, pathetically, a “company town.”  The Company being whatever is the current owner of the Delaware City Refinery.  The Refinery has had perhaps a half-dozen owners since opening in 1957, none seeming nastier or more aggressive that the present PBF Energy. Continue reading

Code Orange bad air day in Delaware (July 12, 2014)

The air quality forecast has worsened.  Officially:  Code Orange on Saturday, Code Yellow through Monday.

In my view Code Orange for ozone plus Code Yellow for particles = Code Red (unhealthy for everybody).

Fortunately, the temperature/humidity/pollen forecasts are not too bad.  But this air quality can still make you sick, especially, if you are young, old, or addicted to breathing.  Take it easy.

Some background info and commentary.

Official forecast below:

From: Penn State Air Quality Forecast Office <psaqfo@psu.edu>

State of Delaware Air Quality Forecast for:

Saturday, July 12, 2014

_________________________________________________________
Ozone (O3): CODE ORANGE (UNHEALTHY FOR SENSITIVE GROUPS)

Fine Particles (PM2.5): CODE YELLOW (MODERATE)

_________________________________________________________

Discussion:

Saturday will be an Air Quality Action Day for ozone for Delaware.  Surface stagnation overnight and through the morning will allow pollutants to accumulate, similar to conditions on Friday.  Mostly sunny skies, light winds, and recirculating flow aloft will promote rapid ozone formation in the afternoon, with daily concentrations reaching the Code Orange range, primarily in northern Delaware.  Particles will also respond to the light winds by rising into the low Moderate range.

A warm front will lift over the region from the south on Sunday, resulting in warm and humid conditions.  Warm air arriving aloft will limit vertical mixing, which will help to keep particles in the Moderate range.  Increasing clouds in the afternoon and sustained southerly surface winds, along with the chance for scattered showers, will limit ozone to the Good/Moderate threshold.  Monday will be hot and humid, with widespread afternoon clouds and precipitation as a cold front slowly approaches from the west.  Ozone will be in the upper Good range, while particle will linger in the Moderate range in the humid air mass.

Huff/Catena/Herdt

Penn State Air Quality Forecast Office (PSAQFO)
The Pennsylvania State University
Department of Meteorology
Website: http://psaqfo.psu.edu/
Email: psaqfo@psu.edu