ASPHALT PLANT ISSUES

 The following is the Glynn Environmental Coalition summary of issues concerning the Air Quality Permit for Sholan Asphalt Plant, 4090 Whitlock Street, Brunswick, Georgia; application No. 16745

1.) The Air Permit would put two asphalt plants 1/2 mile from Brunswick High School, Jane Macon MiddLe School, and Christian Renewal Academy.

The Glynn County Commission objected to the first asphalt plant air permit in 2003 because, "The proximity of this plant to established residential neighborhoods and schools intensifies our concerns about monitored and unmonitored toxic emissions from this plant, including formaldehyde, benzene, and other chemicals and dust which could be injurious to the health of the surrounding residents and children attending schools in the area.”  Numerous residents, parents, and businesses also objected to the air permit.

2.) The Air Permit would result in the Georgia Environmental Protection Division engaging in an activity that causes disproportionately high and adverse human health or environmental effects by its programs, policies, and activities on minority and low-income populations.

Brunswick is 60% minority, 28% live below the poverty level, and the EPA has listed Brunswick as an Environmental Justice community under Executive Order 12898 - Envi- ronmental Justice. Under the order, air permitting should not cause "... disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations.”

Polluting industries can’t all be located in minority and low income areas. Permitting a second asphalt plant in a minority and low income neighborhood would result in a dis- proportionately high impact, and therefore be in violation of the Executive Order. The second asphalt plant would be located next to the currently permitted asphalt plant.

3.) The Air Permit will disproportionately economically impact established businesses in the area.

Business, particularly auto dealerships, objected to the last asphalt plant because they are notoriously dusty. Glynn County Community Development Department visited several asphalt plants in 2004 and noted in their report that blowing dust was a problem.  The report also identified excessively loud noise as likely for any asphalt plants located on Whitlock Street.  Railcar shakers, used to get stone out, have been a chronic problem with asphalt plants located near residential areas.

4.) The Air Permit would result in an activity incompatible with the State plan for a Route 341 "High Tech" corridor.

Impact to the economy in the Rt. 341 "High Tech" corridor from pollution and truck traffic should not be underestimated.  Efforts to revitalize the Rt. 341 area could be dealt a significant blow if polluting industries discourage desirable commerce or investment into the area.

5.) The Air Permitting process should include an evaluation of existing permitted pollution sources, and actual pollution levels.

Georgia Rule for Air Quality Control, 391-3-1.02(2)(a)1, provides guidance and establishes overriding goals for the air permitting program.

6.) Executive Order 13045--Protection of Children From Environmental Health Risks and Safety Risks - is violated by the proposed Air Permit.

The intent of Executive Order 13045--Protection of Children From Environmental Health Risks and Safety Risks --  is to evaluate permitting decisions' impacts to the learning environment of children. The EPD should specifically address our concerns over impacts to our children’s health and ability to learn due to release of hazardous air pollutants near schools.

Hazardous pollutants include potent central nervous system toxicants and suppressants, many of which are released close to Brunswick’s schools, which could reduce the ability to learn or influence test taking ability.

Economic potential of our community is harmed when significant numbers of students do not receive at least a high school education. Critical to the economic future of Brunswick are environmental conditions in schools that foster and support learning potential.  Seven schools are located in areas with unhealthy levels hazardous air pollutants, and many of the schools are located closer to emission sources than the State air monitoring station.

7.) Executive Order 12866 - Regulatory Planning and Review - Is Violated by the proposed Air Permit.

The proposed Air Permit is an example of the regulatory system working against the American people, and not for them, which Executive Order 12866 sought to prevent and rectify.

Executive Order 12866 instructs each agency to provide the public with meaningful participation in the regulatory process. In particular, seek the involvement of those who are intended to benefit from and those expected to be burdened by any regulation.  In addition, each agency should afford the public a meaningful opportunity to comment on any proposed action, which in most cases should include a comment period of not less than 60 days.

8.) The proposed Air Permit application does not include an evaluation of potential impacts from an accident to nearby schools, as noted in the EPA’s Plain English Guide to the Clean Air Act.

The EPA has provided the American people a Plain English Guide to the Clean Air Act in which they provided information about the effects of unhealthy air pollution and actions citizens can take when the State makes unwise air permitting decisions. The Guide states: “Air pollution can make you sick.  It can cause burning eyes and nose and an itchy, irritated throat, as well as trouble in breathing.  Some chemicals found in polluted air cause cancer, birth defects, brain and nerve damage and long-term injury to the lungs and breathing passages.  Some air pollutants are so dangerous that accidental releases can cause serious injury or even death.”

The EPD complaint records have extensively documented the above-described conditions being experienced by citizens, children, teachers and students, and businesses in Glynn County.

9.) The proposed Air Permit would be contrary to Georgia Department of Education Guidelines for Schools, which has specific criteria for selection and maintaining the school learning environment and the health and welfare of the children.

The Georgia Department of Education (GDOE) Guide to School Site Selection (December 8, 2003) has specific recommendations for school environments, which the proposed air permit would violate, or cause existing school to not meet school siting recommendations for a safe and healthy learning environment, and would exacerbate the existing high rate of respiratory problems in area school children.