7:00 pm - 9:00 pm Tuesday, May 21st
Christiana Presbyterian Church
15 N. Old Baltimore Pike
Christiana, DE 19702
Please join us in welcoming NCC Council President Karen Hartley-Nagle to our meeting this month.
June, 18 2019 is our CLNCC Annual Meeting:
Election of Officers
AGENDA May 2019Call to Order
Guest: NCC Council President Karen Hartley-Nagle
Officers Reports
Treasurer
Secretary
Vice Presidents
President
Old Business
New Business
Additional Member Comments
- Bill Dunn will be presenting on the Coastal Zone Regulations Draft
- Asbestos and Lead Sign On Letter to the General Assembly presented by Sarah Bucic;
Dear Civic League of New Castle County,Environmental, health and labor organizations are working together in Delaware to reduce the potential for community exposure to hazardous substances, including asbestos and lead paint, from demolition projects.
Demolition of industrial, commercial and multi-family housing facilities that contain asbestos, lead paint, or other hazardous materials in proximity to homes, parks and schools creates a public health risk.
To prevent community exposures, we have drafted a petition to DNREC asking for regulatory rule-making and a permit structure for demolition where hazardous substances are present. These regulations should include community notification, air monitoring, and emergency plans if something goes wrong.
We intend to submit the petition on June 1.
Please let us know if your group would like to sign on to the petition.
Sincerely, Sarah Bucic, RN
Title 16 of the Delaware Code, Chapter 78. Asbestos establishes an oversight structure by DNREC and the OMB to “ ensure the health, safety and welfare of the public by regulating the practice of asbestos abatement, particularly in locations where the general public can reasonably be expected to have access for the purpose of ensuring that such abatement is performed in such a manner as to minimize exposure to asbestos fibers and contamination.”Anyone can sign the petition as an individual. Click on the link HERE to sign this petition.
§7806 assigns DNREC with the power and duty to “promulgate rules and regulations as are necessary to implement the enforcement aspects of this chapter.”
At present, DNREC does not have an adequate oversight structure for the protection of the public. It lacks basic transparency measures (including community notification) to ensure that the public is notified of the demolition activities, data collection (including air monitoring) to ensure that air quality is not diminished, and emergency response plans on file for when something goes wrong. DNREC does not do random site visits to make sure that proper handling procedures are followed. Because DNREC does not issue permits for asbestos removal, it does not collect permit fees to cover the costs of administering the asbestos removal program.
DNREC Regulations 1102 Permits requires an air pollution permit for all “alteration” activities except those that are exempt in Appendix A. Because Appendix A does not include the demolition of any structure, demolition activities, including the removal of hazardous substances from a site, should fall under DNREC air pollution permits. Demolition activities can cause asbestos, lead paint chips, grit or dust, or other hazardous materials to become airborne in close proximity to homes, parks, schools and ecosystems where it can harm public health and the environment. Because DNREC does not presently have any air permit for the demolition of any structure, DNREC regulations and permitting are incomplete.
As stated on the DNREC website, “The mission of the Department of Natural Resources and Environmental Control is to ensure the wise management, conservation, and enhancement of the State’s natural resources, protect public health and the environment , provide quality outdoor recreation, improve the quality of life and educate the public on historic, cultural, and natural resource use, requirements and issues.”
To protect public health and the environment and to educate the public about demolition
activities, we the undersigned request the initiation of DNREC regulatory rule-making
proceedings for demolition activities where hazardous materials, including asbestos and lead paint, are removed.
We ask that new regulations and a permit structure be developed for demolition activities where hazardous materials, including asbestos and lead paint, are removed, and that these new regulations and permit structure include:
1. Community notification that includes which hazardous materials are being removed, the timeline for removal, and a public health fact sheet about the health effects of the
specific hazardous materials.
2. Air monitoring at the fenceline daily for the duration of the time period when hazardous materials are being removed from the site, with air monitoring results available to the public.
3. A Site Emergency and Release Response Plan prior to issuance of the permit, which
should include: the immediate notification of the public likely to be impacted of the risks
of exposure; a coordinated effort between property owner, DNREC, and the Delaware
Division of Public Health to protect the health of area residents; personal precautions
that can be taken by individuals; a person to contact for questions/concerns at DNREC,
and; a proposed response timeline.
Such regulations and permit structure shall entail associated permit fees to cover the costs of administering the program. Unscheduled site visits by a DNREC site inspector should be included in the provisions to ensure that all permit provisions are being followed. To ease the burden on small businesses and the public, we suggest limiting the scope of these regulations and permit structure to include commercial, industrial and multi-unit housing where the footprint of the structure exceeds 5000 square feet.
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