By: Rachel Meyer, Ohio River Valley Field Organizer
Date: April 7, 2026
About: Proposed Draft Plan Approval PA-04-00740D
To: Pennsylvania Department of Environmental Protection
My name is Rachel Meyer, and I am the Ohio River Valley Field Organizer for Moms Clean Air Force, an organization with over 107,000 members in Pennsylvania united to protect children from air pollution and climate change. My family and I live in Independence Township, Beaver County.
According to the DEP’s website, Shell Polymers Monaca has received 61 Notices of Violation. They have only been operational since November 2022. With this number of violations and nearly 100 malfunctions, the surrounding community and region are being exposed to unreasonable amounts of pollution beyond the limits put in place by the DEP. It is with this in mind, that the proposed draft plan approval D must be highly scrutinized and more strict requirements put in place to protect the environment and people’s health.
We live about eight miles south of Shell. On the morning after a February 10, 2026, benzene release at Shell, my six-year-old daughter came downstairs and told me that she woke up during the night, looked out her window, and saw sunrise. Her window faces north. This is an example of the intensity of the flaring events at Shell. Flaring releases harmful volatile organic compounds and particulate matter.
All this particle pollution adds up and can have terrible effects on children’s health. I worry about how it is impacting my six-year-old daughter. Children are more vulnerable to air pollution. They breathe faster and take in more air per pound of body weight than adults. In our region, thousands of emergency department visits each year for pediatric asthma are the result of particle pollution. It is upsetting to know that living near Shell may be hurting our children’s chances of developing healthy lungs.
Besides worrying about the long-term consequences of being exposed to the high levels of particulate matter in our region day after day, I worry about the consequences of the short-term high levels of exposure that can occur from flaring events. Spikes in daily particle pollution can result in acute health impacts during or soon after a day of poor air quality, such as asthma attacks and hospitalization for respiratory and cardiovascular disease. For me and the almost 17,000 other asthma sufferers in Beaver County, this can mean more days gasping for air especially when combined with the smog formed from Shell’s high levels of VOCs and nitrogen oxides.
Properly functioning flares with the best available technology will emit less of these dangerous pollutants. To ensure that each flare is operating at the highest possible efficiency, the draft permit must be revised to include all applicable requirements for each flare. Every requirement that applies to each flare should be clearly stated or explicitly incorporated into the permit to ensure compliance and maximum transparency. In addition, DEP should revise the Plan Approval to require Shell to conduct periodic performance testing on each flare to determine whether the flares are properly controlling pollution under operating conditions, including as the flares age and degrade over time.
The potential for VOC releases are also very concerning. There is an established association between higher levels of air toxics from petrochemical facilities, such as benzene and 1,3-butadiene, and increased rates of childhood leukemia. Shell has been generating benzene waste in amounts that violate the existing permit limit of 11 tons per year by generating up to 60 tons of benzene waste annually. If DEP allows Shell to generate this much benzene waste, DEP must require additional improvements to the existing monitoring, reporting, and other compliance requirements in the permit, to make sure Shell properly controls this waste and minimizes potential emissions.
An additional issue that must be addressed is Shell’s use of pyrolysis oil. Shell has contracted with a chemical recycling company to acquire pyrolysis oil. Shell has stated on their website that they will use it as feedstock, but that was not mentioned in Shell’s permit application to DEP or analyzed by DEP in this draft permit. Therefore, Shell may not use pyrolysis oil, which can contain many dangerous pollutants, as feedstock at this facility without submitting a new permit application to do so.
Thank you for the opportunity to comment.