This is a blog of the Civic League for New Castle County. It is intended to provide a forum for the posting and discussion of issues affecting the citizens of New Castle County. The content does not necessarily represent the position of the Civic League Board of Directors, as it is intended to be discussion forum to share knowledge and concerns for potential further action.
About Us
Founded in 1962, the Civic League For New Castle County is an organization comprised of community civic associations, umbrella civic groups, good government groups, businesses, and interested individuals. The League provides a forum for education about, discussion of, and action on issues relating to the impact of government on the quality of life in New Castle County
Westminster’s Peace and Justice Work Group will feature a speaker from the Campaign to End Debtors’ Prison. Come learn how Delaware’s laws and policies related to fines and fees unfairly punish those in poverty.
Just last night, the New Castle County Council expressed its will in opposition to the CRODA facility expansion proposal by passing RESOLUTION NO. 20-154 (Read Full Text Below.) Please consider attending the state's two upcoming online meetings regarding this expansion. Registration links can be found below.
The Department of Natural Resources and Environmental Control, Division of Air Quality, will conduct a public information meeting and a public hearing (Docket # 2020-P-A-0018) on the permit application and draft permit for Croda, Inc. (Croda). Croda, having a facility at 315 Cherry Lane, New Castle, Delaware, has requested a federally enforceable 7 DE Admin. Code 1102 construction permit (APC-2020/0070-CONSTRUCTION (FE)) to add a 12,000 gallon drumming tank (Blend Drumming Tank C, Emission Unit 2) to existing Blend Tanks A and B at their facility. The emission increase for the addition of Blend Tank C will be 0.36 ton per year (TPY) of volatile organic compounds (VOC) including 0.17 TPY hazardous air pollutants (HAPs) (primarily dioxane).
Public Meeting
A virtual public meeting will be held on the application on Thursday, July 16, 2020, beginning at 6:00 PM. Please note – this meeting is being held for informational purposes only and is not part of the hearing record generated in this matter.Persons wishing to obtain additional information or ask questions about the permit application or draft permit may attend the virtual public information meeting. Questions on the project, application, and/or draft permit should be submitted in advance of the meeting to allow the applicant and the Department to provide thorough responses. Questions may be submitted by email to daqpermittinginfo@delaware.gov no later than July 6, 2020. The public may attend this meeting via either webcast or phone – visit de.gov/dnrecmeetings for connection information to this meeting.
Public Hearing
A virtual public hearing will be held on the application and draft permit on Tuesday, July 21, 2020, beginning at 6:00 PM. The public may attend this virtual hearing via either webcast or phone – visit de.gov/dnrechearings for connection information to this hearing.Please note that live comments will not be accepted during the virtual hearing. Written comments may be submitted to the Hearing Officer via the online comment form at dnrec.alpha.delaware.gov/publichearings/comment-form/, via email to DNRECHearingComments@delaware.go, or via USPS to the below address. The Department will accept public comment through Friday, July 31, 2020.
Lisa A. Vest, Hearing Officer, Office of the Secretary, Department of Natural Resources and Environmental Control, 89 Kings Highway, Dover, DE 19901
For additional information on the above matters, including how to connect, and to review this application and draft permit, visit de.gov/dnrecmeetings and de.gov/dnrechearings or contact Tracy Mattson, Division of Air Quality, 100 W Water Street, Suite 6A, Dover, DE 19904, by phone at (302) 739-9402, or by email at daqpermittinginfo@delaware.gov
Although the deadline has passed for submitted questions ahead of tomorrow's informational meeting, CLNCC would expect that DNREC will address the issues as put forth in the Council's Resolution (read it below.)
Public Comment on the Air Permit will be accepted at the July 21st hearing and in writing through July 31st.
CRODA VIRTUAL Public Meeting 6PM July 16th - Register for tomorrow's meeting by clicking onto the JOIN ONLINE button below.
Introduced by: Mr. Street, Mr. Carter Date of introduction: July 14, 2020 WHEREAS, Croda, Inc. operates its Atlas Point Facility at Cherry Lane, New Castle, Delaware; and WHEREAS, Croda is closely situated to densely populated neighborhoods and heavily traveled highways; and WHEREAS, at the Atlas Point Facility, Croda manufactures surfactants, which are substances that act as binding agents in other products; Croda uses corn-based ethanol to make Ethylene Oxide, which is the chemical needed to create the binding agents; and WHEREAS, Ethylene Oxide is an extremely flammable gas, is considered to be a human carcinogen, and exposure to the chemical can cause a series of medical problems including skin rashes, breathing problems, and, in severe cases, coma; and WHEREAS, in its relatively brief history in New Castle, Croda’s activities have been a cause for concern – specifically, Croda has had numerous reported Department of Natural Resources and Environmental Control (“DNREC”) environmental violations, which have included:
unpermitted releases of highly flammable Ethylene Oxide, which threatened the health and safety of surrounding neighborhoods and anyone passing by or near the facility, and on at least one occasion was coupled with Croda’s failure to timely report the incident to DNREC and a shutdown of the Delaware Memorial Bridge;
failure to regularly inspect or maintain inspection records for storage areas;
failure to receive necessary approval of its plans (for stormwater and sediment)before it commenced construction;
violations of best management practices related to air pollution;
improper marking on hazardous waste containers;
failure to make a timely application for permit renewals;
failure to monitor or record certain visible emissions; and
failure to provide the required monitoring of erosion and sediment controls;
WHEREAS, in response to one of Croda’s unpermitted Ethylene Oxide releases, in November, 2018, the U.S. Department of Labor’s Occupational Safety and Health Administration found that Croda’s plant had “deficient emergency action and response plans,” failed to train employees on how to manage an Ethylene Oxide leak, did not develop procedures for emergency responders to manage firewater during such a leak, did not activate the emergency alarm system, and also failed to provide employees with respiratory protection; and WHEREAS, despite the serious concerns identified above, Croda has submitted an application for a permit (APC-2020/0070-CONSTRUCTION (FE)) to install two new tanks at its facility: a 12,000 gallon drumming tank (Blend Drumming Tank C, Emission Unit 2) to existing Blend Tanks A and B at the facility, and a 23,000 gallon storage tank for Atplus Destiny final product; and WHEREAS, Croda’s Permit Application discloses that, if its application is approved, this will result in an increase in emissions of volatile organic compounds (“VOCs) and hazardous air pollutants (“HAPs”); specifically, the Permit Application states that the emission increase for the addition of Blend Tank C will be 0.36 ton per year (TPY) of VOCs including 0.17 TPY of hazardous air pollutants (primarily 1,4-dioxane, which the Department of Health and Human Services and the Environmental Protection Agency consider as reasonably anticipated to be a human carcinogen); and WHEREAS, Croda’s Permit Application explains that, although Croda intends to comply with its current VOC emissions limitation, its equipment nonetheless will vent hazardous materials directly into the atmosphere, and that emissions data will not be recorded by a continuous emission monitoring system; and WHEREAS, given Croda’s history of environmental violations, the proposed Permit Application - which admittedly would increase pollutant emissions, and thereby potentially endanger local residents’ well being - is alarming; and WHEREAS, given the above, Councilman Street, on behalf of his constituency, requested that DNREC schedule a public hearing regarding Croda’s Permit Application; and WHEREAS, in his letter to DNREC requesting such a hearing, Councilman Street objected to Croda’s Permit Application based on several grounds, including:
1. Croda’s troubling environmental history, including the November, 2018, Ethylene Oxide leak that led to Croda’s shutdown for almost one year;
2. Many local residents opposed DNREC’s decision to allow Croda to re-start operations after its most recent Ethylene Oxide release and, based on its history, continue to question Croda’s operations and its attention to safety and concern for residents’ health and well being; consequently, the addition of the proposed new tanks will only compound neighbors’ anger and anxiety about their well being;
3. Croda’s emergency notifications and procedures continue to be insufficient to ensure the safety of the facility’s neighbors; and
4. Croda’s operations pose an imminent danger to local residents and all people that use the Delaware Memorial Bridge and nearby roadways.
WHEREAS, in response to Councilman Street’s request, DNREC has scheduled a virtual meeting on July 16, 2020, to provide information only about the project and the Permit Application, with a virtual public hearing on the Permit Application and draft permit to be held on July 21, 2020. NOW, THEREFORE, BE IT RESOLVED by and for the County Council of New Castle County that County Council hereby opposes Croda Inc.’s Permit Application pending before the Department of Natural Resources and Environmental Control and its related request to expand production at its Atlas Point Facility in New Castle, Delaware. Adopted by County Council of New Castle County on: 7/14/20
