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Action Alert !!
Global Proposing Change in Plan
Inconsistent with Consent Decree
We wanted to make sure that you were aware of important information that has arisen regarding the Global tank permit issue. The plan Global has submitted to the Planning Board is not consistent with the Global Consent Decree. As proposed, the design has the potential to increase community exposure to toxic emissions, as described below. And, the changes would make moot the recommendations the city council has put forward to the DEP, as proposed by the Clean Air Advisory Committee (CAAC).
The CAAC recommendations call for monitoring and control of emissions that would only be feasible with the closed airtight system required by the court. Global has presented a plan for a more passive system without the appropriate valves as stipulated in the consent decree. Such a design would undermine the public process and potentially further harm public health.
We are asking that the City Council make its own direct appeal to the DEP and the EPA to intervene and require Global to comply with the consent decree. We also ask concerned members of the public to submit a letter to the EPA & DEP (email addresses below) asking them to require Global to comply with the consent decree for the reasons mentioned above.
jerry.reid@maine.gov Sansevero.christine@epa.gov
See more detailed information about the Global changes to their proposal below. Note: The attorney for South Portland acknowledged in the Planning Board meeting on 6/24 that the Global's proposal was not consistent with the consent decree.
Thank you,
Protect South Portland
_______________________________________________________________
Subject: Consent Decree for Civil Action No. 19-cv-00122-DBH
I am writing to notify you that Global Partners/Companies/Chelsea Sandwich, the defendants in Civil Action No. 19-cv-00122-DBH, have proposed to the City of South Portland to install equipment that is not functionally equivalent to what was agreed upon in the Consent Decree as follows:
- Global’s proposed tank vent hoods are not consistent with the equipment and installation methods they agreed to in the Consent Decree (Civil No. cv-00122-DBH).
- They should be using pressure/vacuum release valves (PVRV) that open with low pressure and/or vacuum, located on top of the tanks at the vents, and allow for the complete capture of vapor emissions from the tanks. The use of these valves ensures that no vapors are allowed to be vented to the atmosphere, and all emissions from the tanks go to the ductwork and the demister/scrubber. They note in the Consent Decree that these will be used and the duct will be tight fitting to eliminate the effect of wind (refer to appendix A, page 45 of 82 in the decree).
- They have now proposed to use hoods that are vented to the atmosphere in place of these valves, as shown in their submittal to the city. These hoods are vented so wind can simply blow and disperse emissions as before. They can simply leave the blower turned off and let everything vent to the atmosphere. If they do run the blower and do not apply enough vacuum, they will not capture the emissions. If they do apply enough vacuum, they end up with a tremendous air flow, as the blower is rated for 2000+ cubic feet per minute, which is at or above the maximum capacity of the proposed equipment.
Section XVII (Modification) of the Consent Decree, notes that the terms of the Consent Decree, including appendices, can only be modified with a subsequent agreement signed by all parties and a material change must be approved by the Court.
If this change was approved, please send me the approval documentation.
If this change was not approved, please inform me what enforcement action will be taken to ensure Global’s compliance with the terms of the Consent Decree.
Regards,
David Falatko
_______________________________________________________
PPH Article on Sprague Consent Decree:
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