BAAQMD: Costs for daily air monitoring too expensive… poor refineries…
By Benicia Vice Mayor Steve Young, October 23, 2018
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.
Announcing the First Refinery and Chemical Industry Emissions Symposium
21st Century Technologies for Quantifying Fugitive and Accidental Releases
The California Air Resources Board (and other sponsors) in partnership with the UC Davis Air Quality Research Center is organizing an educational symposium on the use of modeling for emergency preparedness and response for California refineries. The scope of the symposium will include:
Modeling and monitoring for both routine and emergency operations;
Improvements and enhancements of air modeling, air monitoring, and coordination during significant releases from refineries; and,
Harmonization of modeling and emergency air monitoring with recent state initiatives that require enhanced routine air monitoring at and near these facilities.
Do you have an idea/topic to share? Work you want to discuss with others? Issues you would like a solution? Share your ideas and join our mailing list with Conference Organizer Sandra Hall.
Review of existing/emerging modeling strategies for fitness of purpose and proper application, best approaches for risk quantification and planning purposes, and modeling of cascading effects including offsite consequences of hydrofluoric acid releases;
Use of models for training, drills, and exercises by first responders, industry, and local agencies to prepare for real time considerations during emergency response;
Synergies with newly required air monitoring under AB 617 and AB 1647; and,
Feasibility of enhancing leak detection and repair surveys at refineries and other chemical facilities to a continuous program based on enhanced continuous air monitoring and backward trajectory modeling.
Participants will include CARB, California air districts, U.S. Department of Homeland Security, U.S. EPA, other Interagency Refinery Task Force Agencies, local first responders, industry, academia, consultants, and citizen groups.
Currently our conference topics include but are not limited to:
CARB is the lead agency for California’s fight against climate change, and oversees all air pollution control efforts in the state to attain and maintain health-based air quality standards. Learn more at www.arb.ca.gov.
Sen. Dodd seeks higher fines for illegal refinery emissions
Friday, February 16, 2018
SACRAMENTO – Senator Bill Dodd (D-Napa) introduced a new bill to help deter harmful emissions from oil refineries. The bill would increase fines for serious violations of emissions standards that sicken people or force shelter-in-place orders.
“There are already fines on the books for illegal refinery emissions, but the most common fine hasn’t been increased since Richard Nixon was in the White House,” said Senator Dodd. “When people are sickened by refinery emissions or forced to shelter-in-place, there should be stiffer penalties. My bill reinforces that oil companies should take proactive steps to avoid violations in the first place.”
Dodd’s bill, SB 1144, would triple existing fines for violations of emissions standards if the violations cause a health problem or impact over 25 people. Existing law doesn’t allow increased penalties for violations that injure nearby residents or for refineries with multiple violations. Currently, the maximum amount for the most common level of fines is $10,000 and hasn’t been adjusted since 1974.
Dodd’s bill would set the new fine at $30,000, and if refineries are found negligent, the amount would go up to $75,000 per day. In instances where a refinery fails to correct a known violation or intentionally violates standards, the violations would be even greater. For serial offenders with multiple serious violations within 36 months, the fines could be as much as $500,000 per day.
“Representing communities that house several refineries, I want to encourage the industry to be proactive in meeting their duty to neighboring residents,” said Senator Dodd. “This measure isn’t a silver bullet for addressing safety, but it certainly provides greater incentive to act responsibly.”
Senator Dodd’s district includes the majority of the Bay Area’s refineries. In September 2016, numerous Vallejo residents were sickened by a refinery incident that triggered over 1,500 complaints. The state’s Office of Emergency Services reported that area hospitals and medical facilities treated 120 patients for headaches, nausea, dizziness, and burning of the eyes, nose and throat. The Bay Area Air Quality Management issued a notice of violation to the refinery in Rodeo for that incident.
The funds from the fines in Dodd’s bill would be available to support more robust monitoring and enforcement. The bill is expected to come up for a committee vote next month.
Senator Bill Dodd represents California’s 3rd Senate District, which includes all or portions of Solano, Napa, Sonoma, Yolo, Sacramento, and Contra Costa Counties. You can learn more about Senator Dodd at www.sen.ca.gov/dodd.