Dear Friend, Monroe Energy’s Trainer Refinery in Trainer, PA refines crude oil into jet fuel and other fossil fuel products and is currently applying to renew its permit to discharge treated industrial waste and stormwater into the Delaware River. Clean Air Council is extremely concerned about the contaminants that Monroe is discharging into the Delaware River. The U.S. Environmental Protection Agency (EPA) currently lists the Trainer Refinery as significantly violating the Clean Water Act because of a discharge of Total Organic Carbon (TOC) in November 2023 that was almost seven times the facility’s permitted limit. TOC is a broad measurement of impurities in water that can come from organic sources like decaying plants and animals as well as synthetic sources like chlorinated substances, which Monroe uses in water treatment. TOC is known to react with chlorine to form Disinfection By-products (DBPs) which the Center for Disease Control has concluded may increase the risk of cancer and liver damage if humans are exposed to them. Monroe also continues to record high levels of Total Suspended Solids (TSS) in its water discharges, which is likely caused by erosion of the facilities unpaved areas during rain events. Given Monroe’s history of oil and other chemical spills at the site, high TOC and TSS levels in discharged water, caused by erosion of the site’s foundations, could indicate other harmful contaminants, including heavy metals. DEP should investigate this because, in addition to the spills detailed below, there are additional water discharge pollution sources at the site because in places the foundation consists of up to 21 feet of fill materials, including demolition debris and fly ash from coal plants and incinerators. Such material typically contains heavy metals. To make matters worse, two unrelated oil spills occurred directly adjacent to the Marcus Hook Creek. Additionally, there are over 25 large storage tanks at the Monroe Refinery that are located within the 100-year flood plain. The Monroe Refinery’s low-lying land and its location in the floodplain increase the likelihood that contaminants are entering the Delaware River during rain events via stormwater and an elevated water table beneath the refinery. There are also extremely high levels of polychlorinated biphenyls (PCB) being discharged from the Trainer Refinery’s wastewater treatment facility. EPA considers PCBs a probable human carcinogen and a cause of a variety of other non-cancer health injuries. In Monroe’s current pollution discharge permit renewal application, it reported a 652% increase in PCB discharges from its wastewater treatment plant that could be caused by large amounts of used oil entering the treatment facility from spill recoveries like those mentioned above. It is also very concerning that while the Department of Environmental Protection’s (DEP) proposed water discharge permit renewal requires testing water discharged from Monroe’s wastewater treatment plant for Per- and polyfluoroalkyl substances (PFAS) (also known as “forever chemicals”), Monroe did not include any information about current PFAS testing in its permit application. PFAS chemicals include perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA). In 2016, the EPA concluded that PFOS and PFOA exposure may cause cancer. These chemicals are commonly found in firefighting foam, but unfortunately, DEP is not proposing to require PFAS testing at stormwater outfall 007, which discharges water from Monroe’s dedicated fire training area. Comments are due today, April 1. Click here to submit an official comment demanding Monroe reduce polluted water discharges into the Delaware River.  This is an image of crude oil released from Tank No. 49A (174) on October 6, 2022 into water generated from precipitation around the tank, incident number 58125. Sincerely, Russell Zerbo, rzerbo@cleanair.org, 215-567-4004 x130 | 
