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

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.