Dear Friend,

The Marcus Hook Terminal stores approximately 2,170 tons of hazardous waste at its processing, storage and transfer facility for natural gas liquids in Marcus Hook, PA. These hazardous wastes include neurotoxins like lead and mercury, that are known to damage brain function, as well as carcinogens like benzene. The facility may also store 1,850 tons of “special handling wastes” like the known carcinogen asbestos and the probable human carcinogens polychlorinated biphenyls (PCB), in some circumstances. In order to continue storing hazardous waste at the site, the site’s operator, Energy Transfer Marketing & Terminals L.P., is proposing to renew its 10-year hazardous waste permit under the federal Resource Conservation and Recovery Act (RCRA). This is the first renewal review for this facility since the Marcus Hook Terminal transitioned from an oil refinery to a petrochemical processing plant. DEP should ensure Energy Transfer is not storing hazardous wastes that were generated when the facility was an oil refinery, over 10 years ago. 

Clean Air Council urges you to submit an official comment demanding that the Pennsylvania Department of Environmental Protection (DEP) require Energy Transfer to take actions to better protect public safety and the environment. The hazardous waste stored in 55-gallon drums without a shelter in direct sunlight presents a risk of ignition and fire. Groundwater monitoring has revealed extremely high concentrations of lead and iron in the groundwater and DEP should require a remediation to address this. DEP should also require the applicant to conduct sampling for lead in surface and subsurface soils in areas where concentrations of lead in groundwater are elevated.

DEP should also ensure that Energy Transfer completes this permit renewal application by submitting important information the company failed to provide. For example, Energy Transfer repeatedly fails to include the fact that when industrial waste storage in tank 101 becomes full during heavy rain events, this potentially toxic industrial waste is directly discharged to the Delaware River. 

Energy Transfer also fails to describe how it arrived at the closure cost of the facility. This closure cost estimate is extremely important because if Energy Transfer declares bankruptcy, a third party will be required to remove all the hazardous waste stored at the facility using an insurance bond held by Energy Transfer. It is also important because the applicant has identified contamination in the groundwater and it is not clear whether there is an intention to remediate it. 

Energy Transfer’s practices and failure to disclose critical information to DEP puts our communities at risk of exposure to toxic and carcinogenic materials. 

Please click here to submit an official comment demanding better hazardous waste management practices at the Marcus Hook Terminal.

Comments are due today, February 8th.

Sincerely,

Joseph Otis Minott, Esq.
Executive Director and Chief Counsel

 

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