USACE Wetlands Permit Public Notice

 

Published Dec. 16, 2024

 Expiration date: 1/15/2025

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PUBLIC NOTICE AND DRAWINGS

https://usace.contentdm.oclc.org/utils/getfile/collection/p16021coll15/id/7804

PUBLIC COMMENT DEADLINE January 14 2025

email comments to Project Manager Shelby Barrett shelby.barrett@usace.army.mil

REFERENCE Application MVN 2021 00270 ESG

LOCATION OF WORK:  6500 E St Bernard Hwy, Violet Louisiana 

APPLICANT:  Board of Commissioners of the Port of New Orleans

Suggested Comment Form below from SOS Save Our St Bernard Group Forum

https://www.facebook.com/groups/850309112536823

DATE:

United States Army Corps of Engineers

New Orleans District

Regulatory Division 

Eastern Evaluation Branch 

Project Manager: Shelby Barrett 

shelby.barrett@usace.army.mil 

REFERENCE Application #: MVN-2021-00270-ESG

 Please accept this letter as a response to the December 16, 2024 Public Notice related to the 

above permit application.

 Please accept this letter as a formal request for:

 1. a public hearing related to the above permit application;

 2. an extension of the public comment period of at least ninety (90) days; and

 3. the U.S. Army Corps of Engineers to conduct an Environmental Impact Statement.

Given the magnitude and complexity of the wide-spread effects of the proposed Louisiana 

International Terminal, these requests are reasonable accommodations to allow the community to 

be able to fully and meaningfully participate in this process and have their voices heard.

 

Please take note of my formal objection to the permit application referenced above.  

Below are my top five specific objections to the proposed facility:

1.

2.

3.

4.

5.

There are many more objections to the proposed facility; however, due to time constraints and 

other limitations, I am submitting only my top five objections at this time.

 Sincerely,

                                                                             

(Name and Address)

PBF Energy's Chalmette refinery Title V Permit Renewals

LDEQ PUBLIC NOTICES

PBF Energy's Chalmette refinery 

Title V Part 70 operating air permits 

Renewals and Modifications

1-- No 1 Crude/Coker Units

AI # 1736 Permit 3018-V7 Activity No PER20210007 
Permit Renewal and Modification for the No. Crude/Coker Units
This renewal updates emissions from the units based on the current operating data; Toxic air pollutant (TAP) emissions from the heaters are speciated.

Comments and requests for public hearings must be received by 

4:30pm Thursday, December 26, 2024 

via email to LDEQ, Public Participation Group 

deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 3018-V7 Activity No PER20210007
View Proposed Permit EDMS document 14554993
https://edms.deq.louisiana.gov/app/doc/view?doc=14554993

2 --  No 1 and No 2 Flares
AI # 1736 Permit 3016-V5 Activity No PER20210014 

Permit Renewal and Modification for the No 1 and No 2 Flares
This renewal permit includes 1) updates to the emissions calculations because of updated emissions factors; 2) updates to the specific requirements are applicable; and  3) reclassify No 1 Flare Startup/Shutdown (EQT0269) as an alternate operating scenario (SCN0005).

Comments and requests for public hearings must be received by 

4:30pm  Monday December 30, 2024 via email to LDEQ, Public Participation Group deq.publicnotices@la.gov
REFERENCE AI#1376 Permit 3016-V5 Activity No PER20210014
View Proposed Permit EDMS document 14556566
https://edms.deq.louisiana.gov/app/doc/view?doc=14556566

3 -- FCC Unit and Alkylation Unit

AI# 1736 Permit 3022-V9 Activity PER20210020

Permit Renewal and Modification for the FCC Unit and Alkylation Unit

Emissions from the units were recalculated based on updated emissions factors; applicable requirements revised based on updated regulations.

Comments and requests for public hearings must be received by

4:30pm Monday, December 30, 2024 via email to LDEQ Public Participation Group

deq.publicnotices@la.gov

REFERENCE AI#1376 Permit 3022-V9 Activity PER20210020

View Proposed Permit EDMS document 14559749

https://edms.deq.louisiana.gov/app/doc/view?doc=14559749

4 -- HCU PT3 RF3 LEP Units

AI# 1376 Permit 3015-V6 Activity PER20210012

Permit Renewal and Modification for Hydrocracker Unit, Pretreater No 3 Unit, Reformer No 3 Unit, and Light Ends Plant (HCU PT3 RF3 LEP Units)

In addition to renewing the permit, proposes to revise/update emission factors, remove sources which were added to the PTU/RDU Units permit, segregate fugitive emissions into two source (fugitives and wastewater collection systems), remove hydrocracker splitter reboiler and revise/update for regulatory requirements.

Comments and requests for public hearings must be received by

4:30pm Monday, December 30, 2024 via email to LDEQ Public Participation Group

deq.publicnotices@la.gov

REFERENCE AI#1376 Permit 3015-V6 Activity PER20210012

View Proposed Permit EDMS document 14559745

https://edms.deq.louisiana.gov/app/doc/view?doc=14559745

5 -- Aromatic Units

AI# 1376 Permit 3017-V7 Activity PER20210015

Permit Renewal and Modification for Aromatics 

In addition to renewing the permit, requests to update emissions limitations of storage tanks and add hazardous air pollutant emissions limits

Comments and requests for public hearing must be received by

4:30pm Thursday, January 9, 2025 via email to LDEQ Public Participation Group

deq.publicnotices@la.gov

REFERENCE AI#1376 Permit 3017-V7 Activity PER20210015

View Proposed Permit EDMS document 14569254

https://edms.deq.louisiana.gov/app/doc/view?doc=14569254

6 -- Permit 2933-V8 Activity PER20210002  

Permit Renewal and Modification for No 2 Crude/Coker Units

Revise emissions based on refined calculation methods and updated emissions factors

Comments and requests for public hearing must be received by

4:30pm Thursday, January 16, 2025 via email to LDEQ Public Participation Group

deq.publicnotices@la.gov

REFERENCE AI#1376 Permit 2933-V8 Activity PER20210002

View Proposed Permit EDMS document 14572661

https://edms.deq.louisiana.gov/app/doc/view?doc=14572661

7 -- Permit 3011-V5 Activity PER20210008

Permit Renewal and Modification for Cat Feed Hydrotreater, No 1 Pretreater No 1 Reformer and Gasoline Hydrotreating Unit 

Update emissions rates with revised updated emission factors, and, update emissions rates and operating hours associated with increased throughput.

Comments and requests for public hearing must be received by

4:30pm Thursday, January 23, 2025 via email to LDEQ Public Participation Group

deq.publicnotices@la.gov

REFERENCE AI#1376 Permit 3011-V5 Activity PER20210008

View Proposed Permit EDMS document 14585615

https://edms.deq.louisiana.gov/app/doc/view?doc=14585615

St Bernard Parish & Sulfur Dioxide

 

LDEQ to submit to EPA its revised State Plan for Sulfur Dioxide

Comments Due November 26th  

See LDEQ's pubic notice below

On June 2, 2010, EPA strengthened the primary National
Ambient Air Quality Standards (NAAQS) for Sulfur Dioxide (SO2).

EPA revised the primary SO2 NAAQS by establishing a new health based 1- hour standard at a level of 75 parts per billion (ppb). 

As a result, the EPA designated St. Bernard Parish as nonattainment for the new NAAQS, and the air quality in St Bernard has remained nonattainment since. 

Per a recently public noticed DRAFT revised State plan to bring air quality in St Bernard into attainment, the new air dispersion models used by LDEQ resulted in concentrations of SO2 just below the 75 ppb national standard, with the "highest total impact" reported at 74.8 ppb

With such a small margin of safety, attainment status will require strict adherence to federal air permits. The situation may be even more precarious, as this coastal parish is subjected to more frequent and intense weather events that more often result in excess emissions from shutdown, startup, and malfunction events at the major sources.

Additionally, one of the plants, Rain CII Carbon's Chalmette calciner, is often described as the "lion's share" of the sulfur dioxide emissions. Rain's Chalmette calciner has been challenged in recent years to comply with its air permit's requirement to demonstrate compliance through stack testing. Reportedly, the testing probes were prone to melting under the high temperatures at the stack. 

The focus of the revisions to the SIP for SO2 heavily rely on the Rain CII calciner's ability to comply with a new air permit in an Administrative Order of Consent (AOC) between LDEQ and Rain CII Carbon LLC - Chalmette. The AOC is located in Appendix D of the DRAFT SIP; it has not yet posted to Rain's EDMS files, nor has it pubic noticed in the local newspaper.

The modeled impact for the SO2 SIP revision is based on Rain's waste heat boiler operated at a 900 pound per hour rate. We are completely dependent on LDEQ and EPA to get this right and to ensure compliance with air permits in our parish. They've had plenty of time since the 2010 Standard was established, and meanwhile, public health in our community has suffered.

PUBLIC NOTICE  

The Secretary of Louisiana Department of Environmental Quality (LDEQ) published a public notice in the Louisiana Register that the Office of Environmental Assessment, Air Planning
and Assessment Division, will submit to the Environmental
Protection Agency (EPA) a revision to the Louisiana State
Implementation Plan (SIP) for sulfur dioxide. 

(2410Pot3 located at 1592 or page 176 of link https://www.doa.la.gov/media/3xcacocu/2410.pdf )

The revision is available for review via LDEQ’s electronic
document management service (EDMS), AI# 174156
document number 14513604 dated 10/18/2024
https://edms.deq.louisiana.gov/app/doc/view?doc=14513604

or at LDEQ Headquarters, 602 North 5th Street in Baton Rouge

The SIP revision will implement standards required by the Clean Air Act for the nonattainment area. All interested persons may submit written comments concerning the revision no later than 4:30 p.m., Tuesday, November 26, 2024, to Arlys Dalton, Office of Environmental Assessment, P.O. Box 4314, Baton Rouge, LA. 70821-4314, or by E-mail at arlys.dalton@la.gov

EPA EJScreen Mapping Tools Update

 

Use this EPA EJScreen mapping tool to help identify environmental issues and areas that are disproportionately affected.

https://www.youtube.com/watch?v=HZp3AWDJt5A

https://www.epa.gov/ejscreen

Launch the EJScreen tool  https://ejscreen.epa.gov/mapper/

The map includes 13 Environmental Burden indicators on air quality or proximity to pollution sources. 

Under the Socioeconomic indicators tab, the first indicator is the Demographic index which includes two factors: low income and people of color. The second is Supplemental Demographic index, which includes low income, person with disabilities, education less than high school, limited English speaking, and low life expectancy. There are other Socioeconomic indicators such as, under age 5 and over age 64.

Looking at the Socioeconomic indicators together or individually will help identify socioeconomic issues the community might already be experiencing, and how susceptible the community might be to the environmental burdens.

There are supplemental indexes which combine the environmental and socioeconomic indicators; the intention of these indexes is to show where both environmental and socioeconomic conditions are disproportionately high. There are also indexes that show health disparities, climate related burdens, and, critical service gaps.

The map and indexes can be printed or shared in a pdf report.

Such reports could help decision makers better protect public health, safety, wellbeing, and quality of life in the communities they represent.

As an example:

In St Bernard Parish, the residential district around the Will Smith, Jr Elementary School, has a high national percentile of both the population under age 5 and the population over age 64.

Residents in Violet, Louisiana already experience low life expectancy, as indicated by the 90 to 95 national percentile.  

Currently, this residential district is subjected to diesel exhaust (NATA diesel PM) and PM2.5 particulate matter pollution above the national percentile 80 to 90 percent; some areas are exposed to these pollutants at the 90 to 95 national percentile. Each of these pollutants, diesel exhaust and PM2.5 particulate matter, are known lung carcinogens. Diesel exhaust and PM2.5 reduce lung function growth in children, are linked to premature death, and are linked higher risk to other cancers, including breast, liver, and lymphohematopoietic malignancies. 

 

which America are we building for?

Proposed first phases of a federal infrastructure project for a mega container port in Violet, Louisiana constructed around elementary school, playground, ballpark, and existing residential neighborhoods

Full build-out over one thousand acres forested wetlands previously proposed for community park and natural areas with nature walks

These wetlands are worth preserving

Anyone else wondering if the Biden - Harris Administration's Investing in America Agenda was intended to repeat the past mistakes of further marginalizing underserved communities via federal infrastructure projects? 

Were USDOT discretionary grants meant to be the nail in coffin when funding mega container ports in the middle of existing residential districts? next to an elementary school, playground, and ball park?

Should the Investing in America Agenda include threats to local school districts to sell & relocate OR we'll just build around it?

Would any project that literally creates a physical divide and makes a fence line community from surrounding neighborhoods be considered a “shovel-worthy” goal of building an America for All?

Our State of Louisiana and our nation can progress in intermodal terminals without destroying the idyllic, rural-suburban community in Violet. Alternative business models with alternative sites and or the existing state ports working together would provide more efficient, safer means to meet business needs without creating new sacrifice zones.

DEMAND USACE conduct a Full EIS

DEMAND USDOT review its benefit cost analysis (BCA) 

NO PORT New Orleans

SOS Save Our St Bernard

https://www.facebook.com/SoStBernard/

Send Comments to: 

USACE wetlands permit application MVN-2021-00370-EG

Attn Project Manager Angelle V Greer
via email  angelle.v.greer@usace.army.mil 

LDEQ WQC application 240521-01
Attn Project Manager Elizabeth Hill
via email elizabeth.hill@la.gov

U.S. Department of Transportation - OST
Office of the Secretary
1200 New Jersey Ave, SE
Washington, DC 20590

Demand a Full EIS and BCA review on the significant adverse impact on the human habitat, including the disparate socio-economic affects and degrading public health and air quality from port pollution

Demand a public hearing and / or public meeting in Q&A format for decision makers to receive more input on the destruction of over one thousand acres forested wetlands and the irreparable damage to the community and our parish as a whole.

REFERENCE all Comments

MVN-2021-0270-EG
WQC 240521-01
OCM CUP20240330
MPDG Discretionary Grant INFRA

Board of Commissioners' Port of New Orleans

SOS Save our St Bernard

sostbernard.org

https://www.facebook.com/SoStBernard/

These wetlands are worth preserving

Reserve La highest risk of cancer in the State

 

Official Statement from the Concerned Citizens of St. John Parish

on Denka's Emergency Motion to Delay 90-Day Compliance Period

FOR IMMEDIATE RELEASE:

May 31, 2024

RESERVE, LOUISIANA - On April 9, 2024, the Environmental Protection Agency (EPA) finalized a new rule designed to significantly reduce emissions of toxic air pollutants from synthetic organic chemical manufacturing and polymers and resins plants. The rule targets harmful substances such as ethylene oxide (EtO) and chloroprene, which have been linked to serious health risks, including cancer.

Here are the key implications for Denka Performance Elastomer:

1. Stricter Emission Limits: Denka, the largest chloroprene emitter in the U.S., must comply with tougher emission standards aimed at reducing cancer risks for nearby residents.

2. Fenceline Monitoring: The facility will be required to continuously monitor air quality at its perimeter, ensuring adherence to new standards and providing transparency on pollutant levels.

3. Compliance Timeline: Denka has been given 90 days to meet the new fenceline monitoring and ambient air standards, necessitating significant changes to its operations and control technologies.

Denka, located in St. John the Baptist Parish, Louisiana, produces neoprene and employs approximately 250 people. The plant, situated near an elementary school and in an area known as Cancer Alley, has been at the center of environmental and racial justice debates.

Denka's Response:

Denka has expressed concerns over the 90-day compliance deadline, calling it "illegal and politically motivated." The company argues that this timeframe is insufficient compared to the two-year deadline given to other facilities. Denka has filed an emergency motion with the U.S. Court of Appeals to stay the compliance period, warning that failure to extend the deadline may force the facility to shut down.

Community and Environmental Activists' Perspectives:

• “Over the last eight years, Denka has continued to poison the children at 5th Ward Elementary School and our surrounding community. Our loved ones of all ages are sick and dying but that is not a priority for this Billion Dollar Corporation.  This is a moment of reckoning,” said Robert Taylor, Founder & Director of The Concerned Citizens of St. John (CCSJ).  

• “We are pleased with the HON ruling and its 90-day deadline.  Our community has endured 56 years of toxic chloroprene emissions from DuPont and now Denka.  We should not have to endure another day.  The money Denka spent on lawyers appealing this suggested limit should have been spent on lowering emissions to a safe level for our community,” Tish Taylor, Program Manager CCSJ stated.  

• “I was raised on the fence line of Dupont/Denka and lost many of my family and neighbors. I don’t want the future generations of my family to suffer the consequences of chemical exposure as we did. We deserve better,” Tim Keller, Board of Directors, CCSJ.  

• “We live in fear, local governments in Louisiana could soon be allowed to shield business records from public.  These are complicated situations but the human toll is priority number one,” Larry Sorapuru, Board of Directors, CCSJ, emphasized.  

• Sharon Lavigne, founder of RISE St. James, honors the dedication of Denka workers and their families. "There's dignity in a day's work. Every day, hardworking Americans sacrifice themselves to provide for their families. We recognize the hard work of Denka employees and their commitment to their families. Our fight is for their health and well-being as much as it is for our community’s future. This is an opportunity for a just transition rooted in low-income communities of color, who see the need to phase out industries that harm workers, community health, and the planet. At the same time, we MUST provide just pathways for workers to transition to other jobs, with even better pay in alliance with fenceline and frontline communities."

Background:

In 2016, EPA held an emergency community meeting and reported that Reserve, La had the highest risk of cancer in the United States due to emissions of Chloroprene from Denka/Dupont. They suggested Denka should lower emissions to 0.2 micrograms per cubic meter of air. CCSJ has diligently advocated for the safety of St. John Parish. We have traveled to Japan twice to speak directly to Denka’s Board of Directors but were met with open hostility. Profit is their priority.

The EPA's action follows a broader initiative by the Biden administration to address pollution in communities that disproportionately bear environmental burdens. The rule is expected to reduce cancer risks and improve public health protections.

This statement is issued by the Concerned Citizens of St. John Parish in support of the EPA's efforts to protect our community's health and well-being. We stand with environmental activists and residents in advocating for stringent regulations to ensure a safer environment for all.

ABOUT THE CONCERNED CITIZENS OF ST. JOHN PARISH

At CCSJ, our mission is to advocate for the health and safety of all citizens. Starting with our local councilmember, we are committed to holding government officials and industries accountable for the quality of our air, water, and soil.  Additionally, we strive to secure a safe and promising future for the children in our parish while providing leadership to advance our community in various aspects.  Please contact us directly with all inquiries and funding opportunities as we may require a signed letter of support including a wet signature.  

CONTACT INFORMATION

Robert Taylor

504-559-7304

Tish Taylor

504-417-4732

iluvlaplace@gmail.com

Carcinogenic diesel engine exhaust

 

diesel engine exhaust is classified as "Carcinogenic to humans"

PBF Energy's refinery in Chalmette, St Bernard Parish, and adjacent Rain Carbon CCI calciner are within a 3-mile radius of over 58,700 people, 39% low income, and 60% minority. 

Several areas of St Bernard Parish are exposed to a 95% to 99% national percentile diesel exhaust pollution (NATA diesel PM), and areas of St Bernard Parish which are not so exposed will be if the USACE and the State of Louisiana develop over one thousand acres forested wetlands into a massive international terminaling port.                 -- https://www.sostbernard.org/

The International Agency for Research on Cancer (AIRC) is part of the World Health Organization (WHO) One of its major goals is to identify causes of cancer. IARC classifies diesel engine exhaust as "Carcinogenic to humans." According to EPA, in addition to the lung cancer risk, there is significant potential for non-cancer health effects as well, based on the contribution of diesel particulate matter to ambient levels of fine particles. Exposure to fine particles contributes to harmful respiratory and cardiovascular effects, an to premature mortality.

From Our Friends and Fellow Residents in St James Parish and Members of RISE St James 

Chemical of the month --- PM 2.5     by Caitlion O. Hunter, Esq.

"The combination of high levels of PM in the air with other air pollutants in industrial areas is especially dangerous, since PM2.5 can form from or bind to metals and petrochemical pollution released into the atmosphere. Burning diesel as fuel releases a mix of incredibly small particles as well as carcinogenic chemicals; these two then bind together to make a PM that has been found to cause cancer in humans. "

A service program of RISE St. James; Caitlion O. Hunter, Esq.; Tim Schütz, PhD Researcher, Anthropology University of California, Irvine; and The Community Scientist (TCS) Research Team