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Fall 2002 Newsletter
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Comments on Hercules, Inc.
Title V Air Permit
Highlights of Proposed Permit
Release of 6 million pounds of toxins
a year (3,000 tons)
Includes two dozen toxic chemicals
Allows unconditional release for
as long as four hours
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Related Toxic Contamination
from Hercules in Brunswick
009 Superfund site on Parkway near Colonial Mall
(toxaphene contaminated landfill)
Terry Creek Superfund site
Toxaphene contaminated estuary
Former toxaphene impoundments with related
groundwater contamination
Neighborhood with toxaphene contaminated yards
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Above based on data from US-EPA, GA-EPD and the Glynn Environmental
Coalition
Comments on Hercules, Inc.
Title V Air Permit
On September 3rd, I joined several dozen concerned citizens in attending a
public hearing held by the Environmental Protection Division (EPD) in
Brunswick to explain the Clean Air Act permitting process and to receive
questions and comments about that process at it applies to the current
review of an air quality permit application by Hercules, Incorporated.
Hercules operates an aging chemical processing plant located in an area that
is shared by numerous residential, commercial, and public land uses,
including a public school, a hospital, and many homes of low- and
moderate-income families.
Enormous amounts of community effort (and public
resources) have been invested in identifying, analyzing, and controlling
toxic materials generated by Hercules over many decades of its existence,
mostly accomplished in the past ten years through the initiatives of the
Glynn Environmental Coalition, a grassroots non-profit environmental group,
working through the Superfund Program administered by the federal
Environmental Protection Agency (EPA).
Given the extended period of known
risk exposure from past Hercules activities, offensive smell, and various
identified respiratory health problems linked to Hercules stack emissions
(totaling some six million pounds a year), the public is justifiably
concerned about the prospects of this permit being issued. The following
material is derived from our written comments submitted to EPD and copied to
EPA.
- David Kyler |
EPD has not demonstrated that the Title V permit for Hercules would be in
the public's interest, or that it would become so if issued. The Centeršs
conclusions were based on our assessment of review procedures as described
by EPD, combined with related written materials showing details about
technical assessment and human health risk of the two dozen chemicals
emitted by Hercules at the Brunswick site.
Neither the information available, nor the technical analysis applied to it,
is sufficient to protect the public from the considerable threats presented
by these toxic releases. It is also very troubling that EPD would allow
'accidental' chemical releases by Hercules for as long as 4 hours,
regardless of the content, risk, or frequency of such events.
Furthermore, EPD presented no evidence that testing for the full range of
hazardous constituents and their interactive effects in the ambient
atmosphere was done, or that this testing was at frequent enough intervals
over a sufficient period and under various weather conditions to ensure
reliable assessment.
A case in point of particular concern is the known risk of exposure to both
formaldehyde (released in huge quantities by the nearby Georgia Pacific
plant) and formic acid, 6.4 tons of which are emitted annually by Hercules.
There are likely to be numerous other examples of dangerously elevated risks
from combined exposure within the impact area of the Hercules plant, but EPD
provided no credible assurances that these were adequately analyzed.
In the face of such overwhelming challenges and deficiencies, EPD was
presented with extensive compelling empirical evidence about major
respiratory health problems in the surrounding community. Many residents
believe these problems are linked to Hercules air emissions, possibly in
combination with other ambient conditions in the vicinity. There was no
information offered by EPD suggesting that staff members were familiar with
these relevant public health issues, or that such issues had been adequately
investigated in conducting the permit review.
It is the Center's position that until EPD can demonstrate both (1)
sufficient analysis to ensure that the permit would not "injure people,
unreasonably interfere with the enjoyment of life or use of property," (as
specified in the applicable law) and (2) reliable, accountable procedures
for monitoring and assessment of all operations under such a permit, no
permit should be issued.
In summary, prior to further consideration of this permit EPD should provide
the following:
1. An independent evaluation of the impacts of combined chemical exposures
from Hercules and other industrial emitters in the area.
2. An independent epidemiological study of respiratory and other health
problems of the residents exposed to Hercules emissions.
3. Specifications for mandatory reporting and evaluation of all releases
that are not explicitly permitted, regardless of the duration, frequency, or
composition of these deviations from permitted conditions.
Without such steps and assurances, this permit represents an unjustifiable
risk to the public.
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