Sulfur Dioxide Regulations Should Not Exempt the Delaware City Refinery
The Delaware Chapter of the Sierra Club applauds DNREC for proceeding with regulatory changes to bring Delaware in compliance with the Environmental Protection Agency’s 2010 revised National Ambient Air quality Standards for sulfur dioxide (SO2) for a 1-hour average of 75 parts per billion (ppb). These revised federal rules represent a dramatic decline in the level of SO2, which have fallen to nearly half of the original 1-hour average of 140 ppb in the original EPA guidance in 1971.
While we support the concept of revising these regulations and lowering the 1-hour average, we do have concerns with specific language in the amended regulations. Section 1.2 of the regulations provides for exemptions to the regulations, which adds fluid catalytic cracking to the list of exempted processes, which also include fluid coking and catalyst regeneration.
Fluid coking is an oil refinery process that thermally converts heavy hydrocarbons, including those from tar sands bitumen and heavy whole crudes to lighter products.
Catalyst regeneration is a process used for refineries. Sulfuric acid is used as a catalyst in refinery production. The Sulfuric Acid Regeneration process conducted by the DuPont Red Lion Sulfuric Acid Regeneration Plant regenerates “spent acid waste” from the refinery, which can then be re-used.
Fluid catalytic cracking is a processes used in petroleum refineries to convert crude oils into gasoline, olefinic gases, and other products
The existing exemptions for fluid coking and catalyst regeneration, and the proposed exemption for fluid catalytic cracking from SO2 regulations, provides for an exception for one of the largest sources of SO2 emissions in Delaware, the Delaware City Refinery. DNREC’s November 2012 Delaware Toxics Release Inventory Data Detail found the Delaware City Refinery to be the second-largest polluter in the state, behind the Indian River Power Plant.
Since May 27, 2011 the PBF Delaware City Refinery and the DuPont Red Lion Sulfuric Acid Regeneration Plant have been the sole sources of SO2 Delaware Environmental Release Notification System (DERNS) notices in the state. There were 53 such notifications. 4 of these events have been by the DuPont Red Lion Sulfuric Acid Regeneration Plant. The remaining 49 events were for the PBF Delaware City Refinery.
It is inappropriate to exempt one of Delaware’s largest polluters, the Delaware City Refinery, and its dependent regeneration plant, the DuPont Sulfuric Acid Regeneration Plant, from SO2 regulations which are intended to protect public health.
SO2 is regulated in the NAAQS for important health reasons. The EPA describes these health risks:
“Current scientific evidence links short-term exposures to SO2, ranging from 5 minutes to 24 hours, with an array of adverse respiratory effects including bronchoconstriction and increased asthma symptoms. These effects are particularly important for asthmatics at elevated ventilation rates (e.g., while exercising or playing.)
Studies also show a connection between short-term exposure and increased visits to emergency departments and hospital admissions for respiratory illnesses, particularly in at-risk populations including children, the elderly, and asthmatics.”
Exempting refinery processes from these SO2 regulations presents an unnecessary risk to public health, particularly in communities surrounding the Delaware City Refinery. We therefore ask that all exemptions in Section 1.2 be removed from the final regulations, including fluid catalytic cracking, fluid coking and catalyst regeneration.