Date: June 5, 2024
To:
Brian Carney
West Virginia Department of Environmental Protection
Division of Air Quality
601 57th Street SE
Charleston, WV 25304
Via email: [email protected]
Re: Comments on TEMA North America, LLC’s air quality permit application concerning plastics extrusion facility in Jefferson County, West Virginia
My name is Lucia Valentine and I am the West Virginia Field Organizer for Moms Clean Air Force. Our mission is to protect children from air pollution and climate change. As a community of over 1.5 million moms and dads united against air pollution, Moms Clean Air Force envisions a safe, stable, and equitable future where all children breathe clean air.
Moms Clean Air Force West Virginia is commenting to the West Virginia Department of Environmental Protection Division of Air Quality on the TEMA North America, LLC’s air quality permit application R13-3414A. TEMA North America LLC has proposed to modify a plastic extrusion facility located at 395 Steeley Way, Kearneyville, WV 25430, Jefferson County, WV at 39.356546 and -77.870943.
Plastics are made from fossil fuel polymers combined with more than 16,000 chemicals, many of which are toxic, volatile, and bio-accumulative. These chemicals are linked to cancers and other health harms.
Plastics extrusion is a high-volume manufacturing process in which small plastic beads, known as nurdles, are heated into a molten polymer which is then forced through a die at high pressure and then allowed to harden into shape in a mold during cooling.
Each stage of the plastic extrusion process is heavily polluting. The process is expected to harm workers as well as community members in Jefferson County and beyond.
Plastics extrusion includes the following steps:
- Transporting vast amounts of plastic pellets, called nurdles, and plastics chemicals, on West Virginia roads and rails.
- Heating the nurdles into a molten state, releasing volatile organic pollutants (such as formaldehyde) and hazardous air pollutants (such as dioxins) and other dangerous chemicals (such as PFAS) in the process.
- Adding additional toxic chemicals to the molten plastic to alter the final properties of the plastic and to lubricate the extrusion and molding process. These chemicals can volatize into the surrounding air.
- Forcing the molten resin through a small opening in the die at high pressure – a process that generates fine and ultra-fine particulate matter. Exposure to these tiny plastic particles can cause inflammation and is linked to many health risks and chronic conditions, including asthma, heart disease, respiratory disease, cancer, dementia, endocrine disruption, neurodevelopmental conditions, and adverse birth outcomes.
- Additional off-gassing of VOCs and hazardous air pollutants as the plastic material continues to cure.
- Plastics extrusion facilities commonly store large amounts of plastics, plastics-chemicals, and plastics precursors including nurdles. These materials can pollute air and waterways, harming workers, wildlife, and community members. They also present a significant risk of fires and explosions, as have taken place at plastics processing and storage facilities throughout the nation.
It appears that the TEMA company will be using Polystyrene, Polypropylene, and Polyethylene resins.
It is worth noting that the fumes from extrusion of Polystyrene are considered far more harmful than from most any other type of plastic extrusion.
Likewise, the laminating glue methylene diphenyl diisocyanate (MDI) is known to cause asthma and lung damage in workers and others exposed to it.
We are told that no air quality impact analysis was performed for the proposal because this facility is not defined as a “major source” under a state legislative rule.
Yet the distinction is highly misleading between “major” sources of air pollution (those that emit 10 or more tons per year of a single hazardous air pollutant, or 25 tons per year of a combination) and “not major” sources that emit anything less than those thresholds.
Whatever your definitions, there is nothing “minor” about adding into the air tons of particulate matter, VOCs, and hazardous air pollutants including formaldehyde and acetaldehyde. These amounts of very dangerous chemicals can have life-altering and life-ending effects.
Note that both acetaldehyde and formaldehyde were selected by EPA as among the nation’s most toxic chemicals under the Toxic Substances Control Act.
Acetaldehyde is one of the five extremely harmful chemicals chosen by EPA in December as priority chemicals under TSCA. It is a carcinogen, a mutagen, and a teratogen, and it is the most common carcinogen in tobacco smoke.
Formaldehyde is classified as a known human carcinogen, linked to leukemia and other cancers. It’s further along in the TSCA review process. In its preliminary risk evaluation, EPA determined that formaldehyde poses “an unreasonable risk to human health.” Along with chloroprene and ethylene oxide, formaldehyde is responsible for more of the excess cancer risk in the US than any other hazardous air pollutants.
Here are some additional questions:
What other chemicals will the TEMA facility be using at the facility?
And what else will TEMA be emitting?
There are many more hazardous air pollutants besides those on EPA’s 30-year-old list of 188 chemicals – that old list has not kept up with other lists of toxic air pollutants including the 86,000 harmful chemicals on EPA’s own Toxic Substances Control Act Chemical Substance Inventory.
How will emissions be monitored? In the latest permit available online for R13- 3414A, under Monitoring Requirements, we simply read the word, “Reserved.”
Please elaborate on any plans for stack testing. 3.3.1 addresses stack testing but the text is extremely vague.
Precisely what pollutants will be tested for? How will they be measured? Is this continuous monitoring or only periodic – and if the latter, then with what frequency? Will TEMA receive prior notice when testing will take place? What equipment will be used and what is the sensitivity level of those measurements i.e., the lowest level that the devices are able to detect?
Will there be any monitoring at the fenceline or only at the stack? Fenceline monitoring -- with exceedances linked to prompt analysis, corrective action, and enforcement – is an important way to protect the community.
What air pollution control equipment (4.4.3) will be used, if any, and what happens when it breaks down – does the extrusion process continue to operate? Is there backup monitoring? Is there a time limit? Will the public be notified concerning equipment malfunctions?
Will the public have access to the records described in 3.4.1?
Is information on the chemicals present and air pollutants emitted exempted from the confidentiality provisions of 3.5.2 – or might that information be withheld from the public as well?
Will the public have access to the emissions inventory if the WV DEP chooses to request such inventory under 3.5.5?
What are the testing requirements? We see only “Reserved” at 4.3.
What are the emergency procedures? In the Permit Modification application, we only read the word, “reserved.” (2.12)
Under 3.1.2, Open Burning Exemptions, we read that “no person shall cause, suffer, allow or permit any form of open burning during existing or predicted periods of atmospheric stagnation.” Please explain. Does this mean that open burning *will* be permitted at other times that are not considered atmospheric stagnation?
We have serious concerns about this exposed expansion.
Thank you for your consideration of our comments and questions.
We urge the WV DEP to take every effort to curb the emissions and to protect the health of children and families in Jefferson County and beyond.
Sincerely,
Lucia Valentine, West Virginia Field Organizer
and
Cynthia Palmer, Senior Analyst, Petrochemicals
Moms Clean Air Force