Dear Friend, On Wednesday night at 6 PM, Philadelphia’s Air Management Services (AMS) is holding a virtual public hearing where concerned residents can make their voices heard regarding air pollution from the former Philadelphia refinery and the still-active Schuylkill River Tank Farm (SRTF), an enormous series of tanks for storing oil-related products. The site’s new owner, Hilco Redevelopment Partners, is applying for two air pollution permits, one for a series of active petrochemical storage tanks and another for the equipment that will create air pollution when it is dismantled and removed from the former refinery site. Please click here to register for Wednesday’s public hearing. Even if you cannot attend Wednesday’s public hearing, please continue reading this message and submit Clean Air Council’s recommended comment by email as there are significant problems with the current permit applications. One of the biggest issues in the proposed permits is Hilco’s inclusion of several very large crude oil storage tanks in its demolition permit for the former refinery even though Hilco plans to continue to operate those tanks, and including them in the demolition permit would exempt the tanks from important monitoring requirements for harmful air pollutants. Specifically, if the former refinery was permitted to operate under the currently proposed permit, it would no longer be required to do active benzene monitoring of the tanks. This is especially concerning because of documented releases of the known-carcinogen benzene from the Philadelphia refinery, even after its shutdown. Even after the facility ceased refining operations in June 2019 after a catastrophic fire, benzene levels in 2020 measured along the perimeter were, on average, over three times higher than the standard for taking action to protect public health. Because the state of Pennsylvania and the city of Philadelphia both classify the former Philadelphia refinery as being located in an Environmental Justice (EJ) area, the entire facility should be required to maintain active benzene monitoring and Toxic Release Inventory (TRI) reporting requirements, at least until it is clear that benzene emissions are under the EPA’s thresholds for fenceline monitoring. Since Hilco plans to store and sell remaining crude oil at the site, it should be required to conduct active pollution monitoring until all petroleum storage and sale is complete. This error is particularly egregious because Hilco is attempting to register the SRTF as “Petroleum Bulk Stations and Terminals” while the former refinery site will actually have vastly more petrochemical storage capacity than the SRTF. The tanks at the former refinery site must be regulated as a petrochemical facility as it will have a storage capacity far above 10,000 gallon threshold for being considered this type of source. Classifying these large tanks for wrecking and demolition would exempt this very large petroleum storage facility from federally-required reporting of spills and regular releases of toxic chemicals. AMS should consider all petrochemical storage facilities present at the former refinery, including tanks on both sides of the Schuylkill River, under a single air pollution permit and properly and thoroughly account for all associated air pollution. Please tell AMS to require the strictest air monitoring standards around the former Philadelphia refinery and the Schuylkill River Tank Farm. | 
