Documents

EIP Letter to USDA Rural Utilities Services about Proposed SWEPCO Plant
May 9, 2008
EIP letter to USDA Rural Utilities Service, asking the federal agency to deny requested approvals from two electric cooperatives to buy into the proposed SWEPCO Turk coal plant, in southwestern Arkansas.

Letter to Arkansas DEQ about SWEPCO
May 9, 2008
Letter to the Arkansas Department of Environmental Quality, providing important information on SWEPCOs proposed air permit, specifically, SWEPCOs recent submittal under the federal Clean Air Acts stringent maximum achievable control technology (MACT) requirements for mercury and other toxic emissions.

Houston We Have A Problem
May 1, 2008
Texas residents are exposed to 14 known "toxic hotspots" that are not being addressed currently by industry, federal regulators and state officials and will require a major initiative to protect the public's health, according to a new report issued today by Galveston-Houston Association for Smog Prevention (GHASP), Industry Professionals for Clean Air, Houston; Environmental Defense Fund (EDF), Austin; and Environmental Integrity Project (EIP), Austin. Using Houston - where industry today misses the Houston mayor's May 1, 2008 deadline for cleaning up certain toxic air emissions - as a case study to illustrate the threat to Lone Star state residents, the study also identifies 13 other Texas areas as "toxic hot spots" (in alphabetical order): Bastrop, Beaumont, Bowie/Cass County, Corpus Christi, Dallas, El Paso, Evadale (Jasper County), Freeport, Galena Park and Lynchburg Ferry (Harris County), Port Arthur, Port Neches and Texas City. The dangerous airborne pollutants with long- and short-term health effects in these communities include arsenic, benzene, butyraldehyde, hydrogen sulfide, styrene, and more than half a dozen others with known adverse health impacts.

Database of Oil Refinery Air Permitting Actions
Updated information - including deadlines, document links, and agency contacts - regarding the permitting of all U.S. oil refineries under Title V and the New Source Review (NSR) provisions of the Clean Air Act.
Apr 25, 2008

Refinery Permitting Database 4.9.08
Apr 9, 2008

EIP Urges Maryland Department of Environment to Incorporate Recommendations of the National Research Council for Tighter Regulation of Fly Ash
Apr 3, 2008

BP Whiting Oil Refinery Air Permit Comments
EIP joins other groups in submitting comments to the draft air permits issued by the Indiana Department of Environmental Management (IDEM) for the BP oil refinery in Whiting, Indiana
Mar 25, 2008

Letters to Maryland Department of Environment regarding MACT standards applicable to Millennium Inorganic Chemicals, Inc.'s Hawkins Point Plant
Mar 13, 2008

Press Release: Pennsylvania Citizens, the Sierra Club, and the Environmental Integrity Project Act to Halt Controversial Beech Hollow Waste Coal Plant
Mar 5, 2008
Pennsylvania Citizens, the Sierra Club, and the Environmental Integrity Project gave notice to the Robinson Power Company (RPC) of their intent to sue in regards to the controversy-plagued Beech Hollow power plant in Washington County, Pennsylvania. The Environmental Integrity Project and the Sierra Club are among those seeking to halt construction of the new waste coal plant until plans for the plant are altered to meet state and federal pollution requirements. RPC and the Pennsylvania Department of Environmental Protection (PA DEP) improperly rushed the plant through the original permitting process, skipping several key steps intended to protect public health. The proposed 250 megawatt coal plant would burn waste coal, creating enormous amounts of highly toxic waste ash containing dangerous concentrations of mercury and other harmful pollutants.

Request for Reconsideration submitted to Texas Commission on Environmental Quality (TCEQ) regarding emissions increases at the Flint Hills Refinery in Corpus Christi, Texas.
On behalf of Citizens for Environmental Justice (CFEJ) and the Refinery Reform Campaign (RRC), EIP submitted a Request for Reconsideration to TCEQ regarding increased emissions at the Flint Hills "West Refinery" in Corpus Christi, asking TCEQ to reconsider its Responses to Comments (RTC) regarding monitoring technology (emission factors versus LIDAR), the leak detection and repair (LDAR) program, and consideration of environmental justice (EJ) issues.
Feb 15, 2008

Environmental Integrity Project Urges EPA to Perform Adequate Risk Assessment and Strengthen the "MACT" Standards for Emissions of Hazardous Air Pollutants from Oil Refineries.
EPA's finding of "no residual risk" from hazardous air pollutant ("HAP") emissions from oil refineries, and consequent "do nothing" proposal not to substantively update the maximum achievable control technology ("MACT") standards applicable to refinery HAPs, relies on industry-reported emissions estimates which are so understated as to be practically useless, and does not reflect current levels of technology already in use, as required by the Clean Air Act.
Dec 28, 2007

Environmental Integrity Project Releases Citizen Guide to Participation in Oil Refinery Permitting
A Handbook for Citizen Participation in the Permitting of Oil Refineries under the New Source Review Provisions of the Clean Air Act.
Dec 10, 2007

EIP submits comments to the National Commission on Industrial Farm Animal Production detailing improvements needed in Clean Water Act permits for factory farms
Oct 3, 2007

Iowa Citizens for Community Improvement, the Iowa Chapter of the Sierra Club and EIP Urge U.S. EPA to Withdraw Iowa's Authority to Issue Clean Water Act Permits to CAFOs
Sep 20, 2007
Iowa Citizens for Community Improvement, the Iowa chapter of the Sierra Club, and the Environmental Integrity Project filed a new legal petition urging that the U.S. EPA strip the Iowa Department of Natural Resources of its authority to issue factory farm operating permits due to the state agencys lax oversight in the face of widespread concentrated animal feeding operation (CAFO) violations of the federal Clean Water Act. Despite repeated attempts by EPA and citizen groups to spur IDNR to action, IDNR has resisted making any meaningful progress to bring the growing number of Iowa factory farms into compliance with the federal Clean Water Act. The Clean Water Act allows citizens to petition EPA to withdraw the power of a state to issue Clean Water Act permits.

Clean Air Task Force, Earthjustice release report documenting contamination from coal combustion waste disposal
Sep 18, 2007

Environmental Integrity Project and the Sierra Club urge EPA to strengthen the Standards of Performance for Oil Refineries
EPA's proposed New Source Performance Standards (NSPS) for oil refineries include provisions which allow numerous pollutants and sources to escape detection and adequate limitation.
Aug 28, 2007
The U.S. EPA is currently proposing to overhaul the important New Source Performance Standards (NSPS) applicable to oil refineries, and the proposed rule includes provisions that would make it even harder for the public and federal and state regulators to track emissions. EPA's proposal would, for instance, "clarify" existing rules by eliminating important requirements for continuous monitoring of certain flaring devices, making it harder to obtain accurate emissions data during flaring events that are supposed to be minimized under recent EPA consent decrees. The proposed rule also includes provisions which do not require adequate monitoring and limitation of a number of dangerous pollutants, such as volatile organic compounds (VOCs), particulate matter (PM), sulfur dioxide (SO2), carbon monoxide (CO), and nitrogen oxides (NOx). In addition, the proposed NSPS fail to place any limitations whatsoever on emissions of carbon dioxide (CO2), a major contributor to global warming.

50 Dirtiest U.S. Power Plants: CO2 Pollution Linked to Global Warming on Track to Rise by a Third, Mixed Picture on Other Key Pollutants (2007)
Dirty Kilowatts: States With Most Problem Facilities for CO2 Emissions Are AL, FL, GA, IN, KY, NC, NM, OH, PA, TX, WV, and WY.
Jul 26, 2007
CO2 to Rise Sharply, Mercury Levels Hold Steady, Sulfur Dioxide and Nitrogen Oxide Ease Somewhat; States With Most Problem Facilities for CO2 Emissions Are AL, FL, GA, IN, KY, NC, NM, OH, PA, TX, WV, and WY.

Dirty Kilowatts-2007
Jul 26, 2007

Pennsylvania Citizens Request Department of Environmental Protection Inspect Waste Coal Site Owned by Champion Processing Inc. in Robinson Township, PA.
Apr 30, 2007
Pennsylvania citizens request the Pennsylvania Department of Environmental Protection to inspect potentially illegal activities conducted by Champion Processing Inc., at its waste coal site located in Robinson Township, PA.

Pennsylvania Citizens Urge Governor Rendell to Protect Drinking Water from Coal Combustion Waste
Apr 30, 2007
Residents living near coal-fired power plants and coal combustion waste disposal sites urge Governor Rendell to adopt safeguards to protect drinking water supplies from coal combustion waste as recommended by the National Academy of Sciences in its March 2006 Report, "Mine Placement of Coal Combustion Residues."

NOAA's Assessment of Sediment Data Around Sparrows Point Confirms EIP Analysis
The National Oceanic and Atmospheric Administration confirmed findings of a recent EIP study analyzing the toxicity of sediment around Sparrows Point, Maryland and agreed that additional testing should be conducted prior to further dredging around Sparrows Point.
Apr 23, 2007

Letter to EPA Regarding Possible Lack of Reporting of Formaldehyde Air Emissions from Oil Refineries
Apr 3, 2007

Petition to Veto Federal Operating Permit Issued to Premcor Refinery
EIP Petitions the U.S. Environmental Protection Agency to object to a permit issued under Title V of the Clean Air Act for operation of the Premcor Oil Refinery in Port Arthur, Texas
Apr 3, 2007

Petition to Veto Federal Operating Permit Issued to CITGO Refinery
EIP Petitions the U.S. Environmental Protection Agency to object to a permit issued under Title V of the Clean Air Act for operation of the CITGO Oil Refinery in Corpus Christi, Texas
Apr 3, 2007

Reply Brief: EIP joins five organizations in requesting that the U.S. Court of Appeal for the D.C. Circuit invalidate EPA's illegal Agreement allowing Animal Feeding Operations to defer compliance with the Clean Air Act, CERCLA, and EPCRA.
Mar 13, 2007
In 2005, six organizations, including EIP, filed a challenge to the U.S. EPA's indefinite grant of amnesty from the Clean Air Act, CERCLA, and EPCRA in exchange for minimal fines and payments to finance a monitoring project. Although EPA justifies the Air Compliance Agreement on the basis that it has insufficient data about emissions from Animal Feeding Operations, fewer than 30 of the 14,000 facilities will be required to monitor their emissions. In the petition for review to the D.C. Circuit, the organizations argue that the Air Compliance Agreement is an illegal rule that defers compliance with environmental laws for Animal Feeding Operations.

Letter to Chairman Waxman
Mar 1, 2007

Letter to Honorable John Dingell
Mar 1, 2007

Letter to Chairperson Boxer
Mar 1, 2007

Appendix A
Feb 8, 2007

Numbers at a Glance
Feb 8, 2007

Refined Hazard: Carcinogenic Air Pollution from America's Oil Refineries
Feb 8, 2007

Appendix B
Feb 8, 2007

Statment from Suzie Canales
Suzie is the Director of Citizens for Environmental Justice based in Corpus Christi, Texas
Feb 8, 2007

Appendix C
Feb 8, 2007

Dredge Project in Patapsco River Basin Raises Warning Flags for Aquatic and Human Health
Jan 23, 2007
Analysis of Sparrows Point Shipyard sediment shows levels of lead and other metals, as well as organic chemical concentrations, exceeding National Oceanic and Atmospheric Administration's (NOAA) screening thresholds by as much as 3 to 6 times. The Maryland Port Authority and Maryland Department of Transportation commissioned analysis raises questions as to the impact more excessive dredging for the LNG plant will have upon aquatic and human life.

EIP Opposes Weak Clean Water Act Permit for Confinement Operation in Iowa
EIP submits comments to the Iowa Department of Natural Resources asking it to strengthen its proposed NPDES permit for the Dave Peterson Swine facility in Iowa.
Jan 8, 2007
The first NPDES permit for a confinement operation represents an opportunity for IDNR to prevent further degradation of Iowa's waterways at a time when the state ranks among the nation's highest in fecal bacteria, nitrogen and phosphorus pollution. To achieve this goal, EIP offers a number of recommendations for how to improve the proposed permit and its supporting documents so they comply with the Clean Water Act.

EIP Opposes Seaboard Consent Decree, because it absolves Seaboard of legal liability for violations of the Clean Air Act in exchange for participation in EPA's Air Compliance Agreement.
EIP, on behalf of eight organizations, submits comments opposing the Consent Decree between EPA and Seaboard Farms.
Oct 31, 2006
The Environmental Integrity Project (EIP) submits these comments on the proposed Consent Decree between the Environmental Protection Agency (EPA) and Seaboard Food LP (Seaboard) on behalf of eight undersigned organizations. In its Decree, EPA proposes to withdraw the air monitoring order that it issued to Seaboard in 2002 and absolve Seaboard of legal liability for violations of the Clean Air Act in exchange for participation in EPA's Air Compliance Agreement (ACO). Under the ACO, Seaboard may not ever test its air emissions, nor is the company required to comply with the Clean Air Act (CAA). Accordingly, the groups oppose this decree, because it is bad public policy to put a polluter's interests ahead of citizens' health and to allow companies to benefit from noncompliance.

Presentation: EPA and State Failures to Regulate CAFOs Under Federal Environmental Laws; Outline of Remarks Prepared for the National Commission on Industrial Farm Animal Production Meeting on September 11, 2006
Oct 25, 2006
This presentation outlines EPA and state failures to regulate CAFOs under our federal environmental laws.

Presentation: The Use of CERCLA to Address Agricultural Pollution; Albany Law School-NYSBA CLE-Sept. 15, 2006
Oct 25, 2006
This presentation outlines how CERCLA has been used to regulate CAFO pollution and discusses efforts to exempt CAFOs from hazardous waste laws.

Giving Away the Farm: Why US EPA Should Reject the Ohio Department of Agriculture's Bid to Administer the Clean Water Act
New EIP report details problems with ODA's enforcement and permitting of CAFO's and argues against US EPA authorizing ODA to issue and enforce Clean Water Act permits
Oct 24, 2006

Request for EPA to require Clean Air Act Permits in North Dakota
Sep 21, 2006
Comment letter requesting that EPA require appropriate Clean Air Act permits before allowing contruction of a new refinery in North Dakota.

Dirty Kilowatts: America's Most Polluting Power Plants
New EIP report ranking worst plants on CO2, SO2, NOx and mercury emissions.
Jul 27, 2006

CAFO KPDES Permits and Impaired Waters
Jul 21, 2006

PennFuture, EIP reach agreement with Allegheny Power to clean up Hatfield's Ferry Plant in PA
Jul 13, 2006
PennFuture and the Environmental Integrity Project announced a settlement of its lawsuit against Allegheny Power for violation of soot and particulate matter standards at the Hatfield's Ferry Plant in western Pennsylvania. The agreement requires immediate steps to reduce sooty discharges through flue gas conditioning and other measures, and will further reduce particulate matter through installation of a scrubber no later than June 30, 2010. The settlement is expected to ultimately save over 200 lives and $1.2 billion in health costs annually by reducing exposure to fine particle pollution that triggers asthma attacks and premature death from heart disease