Category Archives: Reactive organic gases (ROG)

Bay Area Air District proposing to give refineries a pass on air monitoring

[Editor: For more, including HOW TO SEND THE AIR DISTRICT YOUR COMMENT, see the Bay Area Air Quality Management District’s Notice of Public Hearing.  Plan to attend on December 19, 2018.  – RS]

BAAQMD: Costs for daily air monitoring too expensive… poor refineries…

By Benicia Vice Mayor Steve Young, October 23, 2018 
Steve Young, Benicia Vice Mayor

The Bay Area Air District (BAAQMD) recently released their proposal on how to deal with the problem of excess ROG (Reactive Organic Gas) emissions from refinery cooling towers. Here are my favorite two sections from their proposed way of dealing (or more accurately, not dealing), with the problem …

Amendments to Rule 11-10 reduce monitoring of cooling towers for hydrocarbon leaks from daily to weekly, with provisions to extend monitoring periods after proving no leaks for an extended time. Costs for daily monitoring were found to be excessive relative to the potential hydrocarbon emission reductions. Requirements for cooling tower best management practices and reporting were eliminated when found to be focused primarily on Process Safety Management and cooling water chemistry rather than leak detection.

The only feasible method to reduce ROG emissions from cooling towers is more frequent monitoring and repair, but this method was concluded to not be feasible due to economic factors as per CEQA Guidelines §15364. Thus, no feasible mitigation measures have been identified that could avoid the significant impact or reduce the impact to less than significant.

Generally, CEQA (the California Environmental Quality Act) does not allow  an environmental impact to be ignored based on the fact that reducing those impacts will cost money. And refineries certainly SHOULD be expected to spend money on such things as more frequent monitoring and repairs.

Going to testify at these hearings – where testimony is limited to no more than three minutes, and often shorter – is both necessary and, seemingly, pointless.

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    Additional comments by environmental expert Dr. Phyllis Fox

    By Roger Straw, April 19, 2016

    Additional comments by environmental expert Dr. Phyllis Fox

    The Benicia Independent is in receipt of an April 18, 2016 letter by Attorney Rachael Koss of Adams, Broadwell, Joseph and Cardozo, representing Safe Fuel and Energy Resources California (SAFER).

    The letter introduces an additional 9-page analysis by environmental expert Dr. Phyllis Fox, “ROG and Benzene Emissions from Unloading Rack Operations.”  (ROG refers to Reactive Organic Gases.)

    Dr. Fox’s new study includes sections on “Railcar Fugitive Emissions At Unloading Racks” and “Other Unloading Emissions” along with several tables.

    This letter was submitted to the City of Benicia within the last hour, and had not yet been posted on the City’s website at the time of this posting.

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      EXPERT REPORT ON LOCAL IMPACTS: Dr. Phyllis Fox rips Valero’s oil train proposal

      By Roger Straw, April 5, 2016

      The Benicia Independent is in receipt of the 92-page expert analysis of Dr. Phyllis Fox, submitted yesterday to the City of Benicia.  As of this posting, the report has not been posted on the City’s website.

      The report focuses primarily on the many significant local impacts and risk factors.  This is highly important, in that the Council is being urged to ignore all of the crucial uprail factors of health and safety that have been identified.

      City staff, paid consultants, the City’s contract attorney and Valero have all cited federal law that protects railroads from local or state regulation. Together, they claim that Benicia’s City Council may not deny or mitigate Valero’s plan based on anything beyond Valero’s small boundary.

      Nearly a dozen opposing attorneys have testified to the contrary, asserting that Benicia has every right to deny a permit to a company like Valero that is NOT a railroad, and to condition any approval on local government and police powers to protect the health and safety of the community and those affected by impacts of the project.

      Should the Council choose to ignore uprail impacts, Dr. Fox’s lengthy listing of local impacts will offer a clear path for a decisive vote to reject Valero’s proposal.  Taken together, the horrific uprail impacts alongside these daunting on-site health and safety impacts make a convincing case for denial.

      Short of denial of the land use permit for the project, Dr. Fox has shown the many fatal flaws and inadequacies of the EIR.  She calls for it to be revised and recirculated yet again.

      Dr. Fox’s table of contents and a significant excerpt follow. (Significant excerpt.) (Complete document.)

      I. SUMMARY AND CONCLUSIONS

      II. ON-SITE ROG EMISSIONS ARE SIGNIFICANT
      ……A. On-Site Fugitive Railcar ROG Emissions Are Significant
      ……B. Feasible Mitigation For On-Site Fugitive Railcar ROG Emissions
      ……C. Storage Tank ROG Emissions
      …………1. Tanks Violate BAAQMD Rule 8-5
      …………2. Feasible Tank Mitigation

      III. ON-SITE TOXIC AIR CONTAMINANT EMISSIONS RESULT IN SIGNIFICANT OFF-SITE HEALTH RISKS

      IV. PUBLIC SAFETY AND HAZARD IMPACTS ARE SIGNIFICANT
      ……A. The EIR’s Quantitative Significance Risk Assessment Is Incorrect and Unsupported
      …………1. The Santa Barbara County CEQA Guidelines Are Misapplied
      …………2. The Santa Barbara CEQA Guidelines Are Not Solely Applicable
      …………3. The EIR’s Quantitative Risk Assessment Is Unsupported
      ……B. Off-Site Risks from On-Site Accidents Are Significant
      …………1. Number of Injuries
      …………2. Number of Fatalities
      …………3. Feasible Mitigation
      ……C. The EIR Fails to Evaluate All Feasible Types of Accidents
      ……D. The EIR Fails to Evaluate All Feasible On-Site Accident Scenarios
      …………1. Accidents During Train Maneuvering at Unloading Facility (Impact 4.7-3)
      …………2. Accidents During Line Hookup And Crude Oil Transfer (Impact 4.7-4)
      …………3. BLEVE (Thermal Tear)
      ……E. Accidents at Other Project Facilities Were Excluded
      …………1. Crude Oil Pipeline
      …………2. Crude Tank Farm
      …………3. Access Road
      ……F. Factors Contributing to Hazard Impact Significance
      …………1. The Location
      …………2. Ignition Sources
      …………3. External Events
      …………4. Centroid Location
      …………5. Other Rail Traffic

      V. FLOODING IMPACTS ARE SIGNIFICANT
      ……A. Flooding Could Increase Hazards
      ……B. The Project Could Increase Flooding
      ……C. Flood Mitigation
      ……D. The EIR Fails to Address Benicia General Plan Requirements

      SIGNIFICANT EXCERPT (footnotes removed here):

      [Benicia’s] Community Development Director (CDD) concluded “the Project’s on-site impacts are mitigated to a less than significant level and all the findings can be made to approve the Use Permit.” Thus, Staff recommended that the City Council overturn the Planning Commission’s denial, certify the FEIR, and approve the Use Permit (3/9/16 CDD Memo).

      SAFER requested that I review the CDD’s conclusions, focusing on on-site impacts. My analysis of the record and additional analyses, documented below, indicate that the Project will result in significant on-site impacts that have not been disclosed in the EIR. These include:

      • Significant on-site emissions of reactive organic gases (ROG) from railcar fugitives;
      • Significant on-site ROG emissions from change in service of existing crude oil storage tanks;
      • Significant cancer, chronic, and acute health impacts from benzene emitted from railcar fugitives;
      • Significant off-site injury and fatality impacts from on-site accidents;
      • Significant off-site flooding impacts from on-site infrastructure and railcars; and
      • Significant off-site injury and fatality impacts from on-site accidents caused by seismic shaking.

      Thus, the EIR must be revised to disclose these impacts, impose all feasible mitigation, and be recirculated.

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