By: Lucia Valentine, West Virginia state coordinator, Moms Clean Air Force
Date: January 9, 2023
About: Title V operating permit renewal for Union Carbide Corporation Institute
To: West Virginia Department of Environmental Protection
My name is Lucia Valentine, and I am the West Virginia Organizer for Moms Clean Air Force. Our mission is to protect children from air pollution and climate change. As a community of over 1.4 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 submitting written comments regarding the West Virginia Department of Environmental Protection Division of Air Quality (DAQ) preliminary determination to renew the operating permit for Union Carbide Corporation (UCC) for operation of its Logistics unit (Group 2 of 2), located within the Institute Facility, Plant ID No. 039-00005, 250 Carbide Road, Dunbar, WV 25064.
We have several public health and environmental concerns regarding the ethylene oxide emissions that are a direct result of Union Carbide Corporation’s operations. We know that the EPA’s most recent study, based on 2018 data, shows the North Charleston area of Kanawha County having one of the highest cancer risks from ethylene oxide emissions in the country, ranking it #21 out of 75,000 areas that may have been exposed to EtO. We are concerned about the carcinogenic emissions and the health risks that this poses to surrounding communities and families, especially children.
Our concerns, as detailed in the preliminary comments submitted on 11/14/22 by Moms Clean Air Force West Virginia, Our Future West Virginia, People Concerned About Chemical Safety, West Virginia Environmental Council, and Earthjustice (collectively, “Commenters”) on Proposed Renewal of Operating Permit for Union Carbide Corporation Institute Facility, Logistics (Group 2 of 2) are as follows:
- Improper Piecemealing of the Institute Facility and its Permitting
- The Draft Permit Improperly Includes an Affirmative Defense for Emergencies
- Commenters Raise Serious Concerns with the Logistics Unit’s Significant Ethylene Oxide Emissions
- The Draft Permit’s Requirements for Operation and Monitoring of the Logistics Unit’s Flares are Inadequate to Ensure Compliance with Emissions Limits and Standards
- There are Significant Environmental Justice Concerns Associated with the Logistics Unit and the Institute Facility
We hope that the The West Virginia Department of Environmental Protection will take these concerns, as well as others made by the public, into account when considering the permit renewal. Curbing EtO emissions is essential in helping to protect the public health of children and families across the state.