[BenIndy editor: Residents of Benicia have for years expressed serious concern about the lack of adequate air monitoring in our “refinery town.” For an excellent background on the lead-up to this important meeting, see Marilyn Bardet’s “Letter to BAAQMD: Must Enforce Refinery Air Monitor Requirements”. Mark your calendar & plan to attend on June 30. – R.S.]
Virtual Meeting on Benicia Community Air Monitoring Site Selection
Invitation to public, sent via email on May 27, 2021
Dear Benicia Community and Stakeholders,
You are invited to attend a virtual community meeting to learn about air quality monitoring and help shape the future of community air monitoring in the Benicia area.
In a joint effort with the City of Benicia, the Air District identified candidate locations in Benicia for a new community air monitoring station. At this meeting, Air District staff will share the sites under consideration and information about how the sites were selected. Community members and stakeholders will have the opportunity to inform final site selection.
When:
The workshop will be held using Zoom and will take place on Wednesday, June 30, 2021, from 6:00 PM to 8:00 PM.
Login information to follow in a subsequent notice.
Why:
The Air District monitors air quality as part of ongoing efforts to inform and protect public health. One of the ways the Air District does this is by collecting fees to install, operate, and maintain air monitoring stations in communities near refineries. These air monitoring stations will provide additional information about the levels of pollution experienced by these communities.
The Air District invites you to participate in this community meeting to discuss and review the site selection process and provide feedback on a community air monitoring station within the Benicia community.
Air District staff want to ensure a fair and equitable virtual workshop experience and provide opportunities for all interested parties to participate. Workshop materials will be available on the Air District’s Special Air Monitoring Projects web page beginning June 7, 2021.
Simultaneous language interpretation can be provided upon request at least 72 hours before the event. Contact Brian Butler at bbutler@baaqmd.gov or 415-603-7721 to request interpretation.
Questions may be sent by e-mail to iperkins@baaqmd.gov.
Para información en español, llame al 415-749-4609
中文聯絡電話 415-749-4609
Nói Tiếng Việt xin gọi 415-749-4609
Working to protect public health, air quality, and the global climate,
Your Air District
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 trust. Unfortunately,in our case, the 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.
Here is filmmaker Constance Beutel’s video of the City of Benicia’s Air Monitoring Workshop with representatives from Benicia Fire Department, the Bay Area Air Quality Management District, Valero and the newly forming non profit, Benicia Community Air Monitoring Program.
The Valero refinery in Benicia. (Craig Miller/KQED)
Solano County inspectors documented a long list of shortcomings and inadequate procedures at Valero’s Benicia oil refinery that contributed to a major pollution release from the facility earlier this year, newly released county documents show.
The county’s Department of Resource Management documented violations of eight separate state regulations. The infractions included failure to fix important sensors in a refinery furnace unit, infrequent inspections of key equipment, and failure to have an operating plan in place to deal with unexpected refinery conditions.
Solano’s probe relied in part on Valero’s root cause analysis of the shutdown, which found that one of the worst refinery incidents in the Bay Area in years was caused by a mistake made months earlier.
Both reports focused on tubes in the refinery’s furnace that heat up crude oil before it’s routed to other parts of the facility for processing. County and refinery officials say those furnace tubes were damaged during maintenance work last November, which caused the devices to fail and contributed to the plant’s malfunctions in March.
The Valero complex ended up belching out a massive amount of black sooty smoke, which led to health concerns for people living nearby.
The refinery’s subsequent closure contributed to a statewide spike in gasoline prices and prompted investigations by several government agencies, renewing attention on the refinery two years after a power outage caused a major release of toxic sulfur dioxide in the area.
Valero spokeswoman Lillian Riojas declined to comment directly on the company’s violations. Instead, she pointed to the company’s May filing with the Securities and Exchange Commission in which it reported it’s facing more than $342,000 in fines in connection with the incident. The company told the SEC it expects to face $242,840 in proposed penalties from Solano County and $100,000 from the Bay Area Air Quality Management District.
Valero’s root cause analysis, completed in July, examines a series of problems that led to the refinery malfunctions.
Company inspections during the refinery shutdown found that furnace tubes were bulging and leaking. Valero says when the facility was restarting a unit last November, a safety valve improperly “lifted,” allowing crude oil to bypass one of the refinery’s furnaces.
Valero says “it was not appreciated at the time” that allowing the bypass “exposed the furnace tubes to elevated temperatures.” Extreme heat gradually deformed the tubes and allowed a solid substance called petroleum coke to form inside. Valero’s analysis concedes that the deteriorating conditions were “not timely identified and mitigated, leading to the tubes’ subsequent failure” and the March refinery malfunctions.
Solano County’s investigation reported that carbon monoxide and oxygen sensors in the refinery furnace were not operational for at least three years.
“Proper functioning sensors would have provided an indication that the furnace was malfunctioning to Valero staff, allowing them to act sooner to correct the condition and prevent additional release,” said Terry Schmidtbauer, the county’s assistant director of resource management, in an email.
“The issue with the furnace upset the system,” Schmidtbauer said.
Those system issues became more evident in early March as two other refinery components experienced problems. One was a fluid coker, which heats up and “cracks” the thickest components of crude oil processed at the refinery. Another, a flue gas scrubber, removes fine particles before gases are released from the facility’s smokestacks.
Malfunctions with those devices led to an increase in carbon monoxide levels, according to Valero, To reduce those levels, refinery crews ended up increasing the temperature on the furnace tubes, thus accelerating their deterioration.
There was little liquid in the tubes, which puts them at risk of damage, according to Professor Eric Smith of Tulane University’s Energy Institute, who specializes in refinery operations.
“One result is thermal degradation of the metal tube,” said Smith, who reviewed company and county findings. “Another effect is that the liquid that does make it through the tube is converted into petroleum coke.”
That dynamic led to the release of sooty smoke and resulted in elevated levels of particulate matter and a health advisory.
County inspectors discovered several problems with lines that carry petroleum coke. On the day the refinery was shut down, one was leaking. Valero staff told Solano officials in April another line had failed five times in the last three years.
The county’s Department of Resource Management has ordered Valero to make a series of changes, some of which it has already completed. They include orders to reduce petroleum coke releases, new procedures for preventing the overheating of furnace tubes and increased training.
Solano County’s Schmidtbauer said the department was still assessing what penalties it will levy against the refinery.
Local air regulators issued 12 notices of violation against Valero. Ralph Borrmann, a spokesman for the air district, said the agency’s probe is not yet complete.
An investigation by California’s Division of Occupational Safety and Health, Cal/OSHA, is expected to wrap up in the coming weeks, according to agency spokesman Frank Polizzi.
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