Category Archives: Air Quality

Letter from Benicia’s Marilyn Bardet to BAAQMD: Must enforce refinery air monitor requirements

Copy of Marilyn Bardet’s letter, forcefully asking the Bay Area Air Quality Management District to follow through on promised enforcement of refinery air monitoring standards


Marilyn Bardet

From: Marilyn Bardet <email>
Subject: BAAQMD oversight/enforcement of Reg 12 – Rule 15, the Petroleum Refining Emissions Tracking Rule.
Date: October 21, 2020 at 3:37:37 PM PDT
To: Marcy Hiratzka <email@baaqmd.gov>

October 21, 2020

BAAQMD Board of Directors
Chair: Council member Rod Sinks, City of Cupertino
Vice Chair: Supervisor Cindy Chavez, Santa Clara County
Secretary: Supervisor Karen Mitchoff,  Contra Costa County

Sent via email:  <email@baaqmd.gov>

Subject:    BAAQMD oversight and enforcement of Regulation 12 – Rule 15, the Petroleum Refining Emissions Tracking Rule.

Dear Chair Rod Sinks, Vice Chair Cindy Chaves, Secretary Karen Mitchoff and Direrctors

I’m writing  as a 34-year resident of Benicia and a founding active member of the Good Neighbor Steering Committee, [“GNSC”] which was organized in 2000 to address public concerns and protect community health and safety as related to operations of the Valero refinery. I’d hope to express the following concerns at the Special Meeting held as a webinar today, but was unable to do so.

On August 1st, the Board received emailed letters from Jay Gunkelman and myself, outlining problems to date with refineries’ fenceline monitoring systems’ performance and reliability.

As you recall, Rule 15 was adopted in April, 2016. It required Bay Area refineries to install new, best technology fenceline monitoring systems, with raw data to be collected in real time at 5 minute intervals, and with a website provided for public access to that data.

After 4 years since Rule 15’s adoption, for the sake of public health and community safety, we would have expected by now that the Air District would have enforced standards for reliable performance of fenceline monitoring systems at all Bay Area refineries, and that data quality would be assured. Yet, to date, as per Rule 15 protocols, the District has not yet signed off on—e.g., given final approval of— the refineries’ fenceline monitoring and quality assurance plans. This is an unacceptable situation.

Today, we encourage the board and staff to fully address the various problems associated to Rule 15’s implementation at all Bay Area refineries. 

Pertinent to the Benicia community, Valero recently asserted that their Benicia refinery will be “the last man standing” among Bay Are refineries, and will continue to refine crude oil and produce petroleum products. Emissions tracking and fenceline monitoring will continue to be of particular concern to Benicians. The reliability of Valero’s fenceline systems’ performance is in serious doubt. 

In 2017, as per Rule 15 Guidelines, the GNSC submitted substantial comments to the District on Valero’s plans that had been created by Sonoma Tech for Valero.

In late 2019, the Benicia City Council voted to encourage Valero to get their fenceline systems installed and up and running before the District’s original deadline. Valero complied, installing 3 pathway systems and creating a public website to provide access to the data collected. Later, when public questions began to arise, Valero said that the new Hydrogen Sulfide monitoring system they’d purchased had never been field tested. After a year’s worth of data collection, data reliability remains questionable even for “signature” gases, including benzene. According to the Federal EPA’s Benzene Fenceline Monitoring Program, Valero’s benzene emissions were not only found to be the highest in the Bay Area; Valero’s total benzene emissions are four times greater than the four other refineries in the region.

It is implausible that there would be so few reportable detections, as the website routinely reports. Repeatedly, the website indicates that instruments are offline, or data is “pending final review.” Whose review? There is apparently no public access to archived data. Good science requires independent validation of data. Credibility of the systems and the data collection is at stake. Without independent review, public confusion and doubt about the sytems’ reliability will persist.

Right now, there is no independent, 3rd party data analysis required by the Air District. Yet verification of data for accuracy is crucial to public trustUnfortunately, in our casethe District has still not yet approved Valero’s fenceline monitoring system plan including the required quality assurance plan as mandated by Rule 12-15.

In the meantime, concerned Benicia residents formed a non-profit, incorporated in 2019, to provide an independently operated, community-based air-monitoring station for Benicia, called Benicia Community Air Monitoring Program. The system will be operated by solar, and will meet international standards for data quality. (Funding was appropriated through GNSC’s urging amendments to the  Settlement Agreement negotiated with Valero and City of Benicia.) We expect the new station will be operational by the end of 2020.

How is it possible that a small community group in Benicia can locate, configure and install an array of air monitoring equipment in less than a year, while the refineries in the Bay Area are still installing technologically inferior fenceline systems four years after they were told by the BAAQMD that these systems had to be approved and proven reliable, thus producing accurate data by now? 

I reiterate my request made in my letter of August 1st: 

We ask the Board to compel Valero to present all of the data associated with these systems to the public as soon as possible. In addition, we would like to see all raw data produced by the fenceline system at Valero so that it can be reviewed by independent experts. We ask that the  public have access to all District staff comments on refineries’ monitoring plans including quality assurance plans.

Thank you for your timely consideration of these matters.

Respectfully,

Marilyn Bardet
Benicia CA 94510

VIDEO: Benicia candidate forum on Air Quality and Refinery Issues

Many thanks to Benicia’s Good Neighbor Steering Committee for hosting this important event!

Video by Constance Beutel for the Good Neighbor Steering Committee

The Benicia Good Neighbor Steering Committee wants to thank all the participating Mayoral and City Council candidates and those who attended the Educational Forum on Air Quality and Refinery issues on October 5, 2020.

The Zoom webinar was recorded, and is now available on Youtube (and viewable below). There are several viewing options, including the full video from start to finish, as well as individual candidate videos highlighting each candidate and their responses to the Good Neighbor Steering Committee questions.

While watching, you may want to view or download a copy of the 9 questions asked each candidate, including excellent background material.

Below are the videos and Youtube links.

[BenIndy editor: Note that each video begins after a 20-second “title screen” followed by an 8 minute introduction by Marilyn Bardet.  After watching those sections once, you may want to jump ahead to the first question at 8:00 or the candidate response, beginning around 8:45. – R.S.]

Full video, start to finish:   Good Neighbor Steering Committee City Council and Mayoral 2020 Candidates Forum: October 5, 2020  
Christina Strawbridge, Mayoral Candidate: https://youtu.be/zy6CH3sgU-w
Steve Young, Mayoral Candidate:  https://youtu.be/DW0pl3MgLP4
Tom Campbell, City Council Candidate:  https://youtu.be/26cNpMEqqb0
Trevor Macenski, City Council Candidate: https://youtu.be/j7gtD4XqV1Q
Terry Scott, City Council Candidate:  https://youtu.be/pHaONqUlL6I

Good Neighbor Steering Committee Candidates’ Forum on Air Quality and Refinery Concerns, Benicia, Mon. Oct. 5

Press release, via email…

GNSC Candidates’ Forum, Benicia
Topic: Air Quality and Refinery concerns
Monday, Oct 5th, 2020, 7 p.m. to 8:30 p.m.
See Zoom link below…

We, the members of the Benicia Good Neighbor Steering Committee, cordially invite you to join us for an educational Benicia City Council and Mayoral Candidates’ forum on issues relating to Air Quality and Refinery concerns.

Candidates have been given 9 questions prior to this forum. The candidates will have 3 minutes to respond to each question. The Zoom forum will be recorded and links will be provided to the community for viewing later.

Marilyn Bardet, Mary Frances Kelly Poh, Nancy Lund,
Kathy Kerridge and Constance Beutel
Good Neighbor Steering Committee
(A refinery and community watch dog on community environmental health and safety issues)

Join Zoom Meeting
https://us02web.zoom.us/j/88625849949 ?pwd=Uk5EU09wRll0NlpGTFlRSEUrL2ZzQT09

Meeting ID: 886 2584 9949
Passcode: Local
One tap mobile
+16699006833,,88625849949#,,,,,,0#,,225810# US (San Jose)

Marilyn Bardet – mask recommendation

From my friend, Marilyn Bardet, September 12, 2020

Marilyn Bardet

Hello dear Friends and Family,

By now I’m sure that each of you has your routine, mask-wearing habit down for social distancing and for simply breathing outside in our smoky air.

But, do you like your mask?

Is it protective against Covid AND smoke (deadly PM2.5 — invisible particulate matter at 2.5 microns that sticks in your lung tissue and sends its toxic gases into your bloodstream)? The invisible particles carry more than dead trees into your lungs, but also the chemicals found in everything combusted in these gross fires: burned out houses, cars, electrical infrastructure, facilities of all kinds. . .

So, your mask needs to be protective for both Covid AND PM2.5.

But, from the evidence I see when I’m out, many people still don’t know that a cloth or paper mask for Covid will not protect against PM2.5. Children, the elderly, and persons with chronic respiratory disease (asthma, COPD, bronchitis) are particularly vulnerable to the risks of exposures to PM2.5. Please tell your friends and family who may not yet know about this.

So, given the amount of smoke and the number of days and weeks we’re facing in Fire Season this year, I’ve done some research and tried out a few types of masks that protect against both Covid and PM2.5.

My criteria: mask must be well designed, fit tight but feel comfortable and breathable for extended use. I do not want to buy disposable “throw-away” type that must be discarded after one day’s use. (This doesn’t apply to medical professionals!!)

So, the reusable/disposable ones I’m recommending are called KN95 masks. Different companies make them.  I like the type that has a metal nose piece hidden inside the fabric. These non-cloth masks fit snuggly around the face, are light weight and breathable. They can be reused, but are not washable.

AMAZON – 20 Packs GB2626-2006 Facemask, PM2.5, Non-woven Fabric, Purifying and Breathable, with Nose Bridge Clip https://www.amazon.com/GB2626-2006-Non-woven-Purifying-Breathable-Haze-Proof/dp/B08HMHQQ9L/ref=pd_lutyp_rtpb_5_1/136-7058495-2219545?_encoding=UTF8&pd_rd_i=B08HMHQQ9L&pd_rd_r=451536cb-05eb-43f1-9bcf-258a65423e02&pd_rd_w=SYWIM&pd_rd_wg=43VeT&pf_rd_p=a6e2c5ee-564b-4b8f-b08c-

grim mug shot de moi, outside studio door, Sept 10, the day after the apocalyptic “red” day.  Oops! my glasses should not have been worn under the mask but on top of it!

ANOTHER TYPE I HIGHLY RECOMMEND:

The GMASK-Graphen Breathing Mask that’s made of a specially patented light weight material (called Graphene), which according to the manufacturer is the strongest, most durable flexible material ever made.

It’s very comfortable to wear, breathable, hand washable, has a pocket inside to put replaceable PM2.5 filters. You can order it at Amazon, in black or grey.

Modern Domus Graphene Face Mask Washable with Filters – Reusable Mask with 5x PM2.5 Carbon Filters (1 Mask + 5 Filters) – Protective Anti Pollution Dust Proof Cotton Mouth Cover (Large, Gray) – – Amazon.com

If you don’t know about “Purple Air” yet, check out <purpleair.com/map> often during the day to get a report on PM2.5 levels in your town….

Well, enjoy the bit of sun peeking through the ashy haze.

Take good care of yourselves, stay safe indoors when the air quality is so poor.

🙂 Marilyn