By: Lani Wean, West Virginia Field Organizer
Date: August 26, 2026
About: UCC Permit Applications (WV DEP DAQ) R13-3727 and R13-1991D
To: WV Department of Environmental Protection
My name is Lani Wean, and I am the West Virginia Field Organizer for Moms Clean Air Force, a national network of moms, parents, and caregivers fighting to protect children from air pollution and toxic chemicals. Thank you for this opportunity to ask questions and comment on Union Carbide Corporation’s recent applications regarding their Institute, West Virginia campus’ logistics and catalyst facilities.
As a local resident living in Charleston who has to breathe the carcinogenic air pollution from Union Carbide’s heavily polluting facilities in our valley, I am deeply disturbed by the extent to which UCC has maneuvered to sidestep Clean Air Act rules over the years, to the proven detriment of our community here. These permit applications are just the latest of these manipulative attempts.
A few years ago, UCC splintered itself into a multitude of separately permitted business entities to circumvent major source aggregation and cumulative hazardous air pollutant reporting requirements (for ethylene oxide and other toxic chemicals) and Maximum Achievable Control Technology standards.
This is a common tactic used by the chemical industry, and one that is, unfortunately, once again relevant to UCC’s operations. UCC is trying to reclassify its two remaining business units—the logistics plant and the catalyst plant—from major sources to area sources to avoid any numeric limits at all on ethylene oxide.
This is an incredibly cynical and deceptive move by UCC, and we aren’t falling for it. So tell me, why are you?
As you well know, UCC’s Institute facilities have a tarnished record of chemical leaks, disasters, and fires, and these facilities are a huge source of the potent carcinogen, ethylene oxide. Exposure to ethylene oxide in the air increases risks of breast cancer and lymphoid cancer. Children are particularly vulnerable to this mutagenic carcinogen—it damages and permanently alters their DNA.
In recent years, studies done by the WV DEP and EPA have shown that community exposure to ethylene oxide near UCC’s Institute facility is alarmingly high. The area is known as a ‘cancer hot spot’ or ‘sacrifice zone.’ The health of our families should not be sacrificed.
The WV DEP Department of Air Quality must not grant UCC’s permit applications to reclassify the logistics and catalyst plants as area sources.
A common response to mentions of UCC’s Institute campus is—‘what’s happened now?’ as community members expect new horrors at any given moment. More carcinogenic air pollution is the LAST thing we need here in the Kanawha Valley.
Our communities are still reeling from the major chemical disaster that occurred here just four months ago, while decommissioning the Catalyst Refiners Inc. facility near UCC’s Institute campus. This disaster killed two workers, critically injured four, and sent dozens to the hospital in need of treatment. New information shows that the company did not even require employees to wear respirators during decommissioning ... and never provided or required workers to use personal gas monitors.
Given this record of dangerous levels of pollution and disasters in the area, it baffles me that the DAQ would seriously consider reclassifying any facilities on this campus in a way that would subject them to less stringent regulations and monitoring.
UCC’s reclassifications under R13-3727 and R13-1991D would increase the risk of serious illness for my household, for children in the area, and my friends and neighbors. It is time that the WV DAQ holds UCC accountable for the total emissions of the Institute facility.
We urge you to protect our children and families and all people throughout the Kanawha Valley. Thank you.