Correspondence
We object to the permit application prepared for the Delaware City Refinery's marine vapor recovery project, also known as the rail-to-ship crude oil transfer project, as it would dramatically increase air pollution and is too ambiguous and vague to protect human health and the environment.
Public hearing comments on amended regulations for the 1-hour National Ambient Air Quality Standard (NAAQS) for Sulfur Dioxide in Delaware, which would exempt refinery processes. The Delaware City Refinery is the largest source of sulfur dioxide emissions in Delaware, and is the largest contributor to emergency notifications for sulfur dioxide releases in the state, and should therefore not be exempt from regulations that are designed to protect public health.
Our compete comments in support of the Sustainable Energy Utility at the Joint Sunset Review Committee hearing on April 9, 2013.
We understand that the task that DNREC has been assigned in the review of environmental regulations for Executive Order 36 is to solicit input through a "focused and targeted review of areas in which existing regulations may be reduced or streamlined..." We hope that DNREC will also consider areas where environmental regulations are protecting the environment and public health, and seek to preserve this valuable contribution to quality of life in Delaware. We also ask DNREC to consider areas where regulations are not adequately protecting the environment and public health, and therefore need to be strengthened.
The Delaware Chapter of the Sierra Club has concerns pertaining to the Environmental Impact Statement for the City of Rehoboth Beach proposed ocean outfall. While the EIS attempts to weight the strengths and weaknesses of the ocean outfall option in comparison to other wastewater treatment options, there are numerous shortcomings in the report, rendering it inadequate to understand the environmental impacts of the project.
We are writing to request a public hearing for the Delaware City Refining Company’s Regulation 1130 (Title V) State Operating Permit AQM 003/00016. The permit application describes dramatic increases in air pollution: increase in Total Suspended Particulates by 29%, increase in Sulfur Dioxide emissions by 4.7%, increase in Carbon Monoxide emissions by 14.2%, increase in Volatile Organic Compound emissions by 12.3%, increase in Sulfuric Acid emissions by 17.2%, increase in Ammonia emissions by 15.9%, and increase in Lead emissions by 33.3%.
The Delaware Chapter of the Sierra Club opposes this plan for Remedial Action for Operable Unit 2 of the Burton Island Ash Disposal Site as inadequate to protect public health and the environment.
The Delaware Chapter of the Sierra Club asks the Joint Finance Committee to consider the risks posed by the Delaware City Refinery on public health and to finance actions by DNREC to protect our communities.
