The Benicia Independent makes it easier for you to read comments of INDIVIDUAL state and regional agencies and organizations. See our updated Project Review page (or just see below).
Something UNUSUAL happened in Benicia on September 15, the final day of the public comment period on the Draft EIR on Valero’s Crude By Rail proposal. I understand that opponents of a project will almost always wait until the last day to submit public comments. But not only did a remarkable NUMBER of critical comments arrive in the City of Benicia’s inbox on September 15 – there was a dramatic landslide of comments from significant governmental agencies and environmental organizations, including…
Valero’s Promise to Benicia: We’ll only have an environmental disaster once every 111 years.
Actually, that’s kind of worrisome, especially considering that if you don’t experience that disaster yourself, your kids probably will. This is one of the many absurd elements showing Valero’s cavalier attitude toward public safety in the draft Environmental Impact Report (EIR) for its proposed crude by rail project, for which public comments were due this week. The hazard analysis in this report is also a serious underestimate, according to the State among many others: The California Public Utilities Commission notes the serious failure of Valero to address the “potential for tragic consequences of crude oil tank car ruptures” from its proposed Crude by Rail Project.
Valero’s Promise to Benicia: We’ll only have an environmental disaster once every 111 years
This dangerous crude project is so riddled with problems that many communities up-rail are now voicing serious concern. The City of Sacramento highlights the high concentration of people around the rail freight lines (“more than 147,000 City residents live within ½ mile”) serving the “Valero Benicia refinery [which] is one of two California refineries that are in the process of securing permits to build rail terminals to import Canadian tar sands and Bakken crude oils.” (emphasis added) And the City of Davis suggests that the “highest levels of protection [be implemented] before disasters such as hazardous material releases and explosions occur [so that] we can avoid having such disasters in the first place.”
Benicians for a Safe and Healthy Community explain why the project is fatally flawed with 132 pages of concerns. Valero’s crude by rail proposal is like so many other projects popping up all over the nation in a mad rush to access cheaper, extreme and dangerous crude oils, with little regard for public health or safety. This project is a total disaster (based on NRDC, CBE and other comments) because it brings:
More Refinery Pollution: Bringing in extreme crudes like tar sands and fracked Bakken crude will only increase refinery pollution. Valero’s Benicia refinery already releases 70 percent more toxic chemicals than the average for California.
Toxic Plumes Along Rail Lines: This thing called “crude shrinkage” happens during transport, where entrained gases escape, leading to a 0.5 to 3 percent loss of crude oil. It’s a big problem for volatile crude oils like Bakken, and coupled with the high benzene levels found in some North American crudes (up to 7%), it creates a serious toxic plume around rail lines. For instance, we estimate over 100 pounds per day of excess benzene emissions from the Valero proposal in the Bay Area (or 1800 times more than the draft EIR reports).
Extreme Crudes are Dangerous: Valero and other oil companies pretend that they can mix extreme crudes like tar sands and fracked Bakken into the ideal “Alaskan North Slope look-alike” crude, which sounds great, except that it doesn’t work that way in reality. Both Bakken and tar sands carry their dangerous properties into any crude oil blend making it more volatile, toxic, and corrosive.
CBR Terminals at Refineries Amplify the Hazard: Valero proposes to site its crude by rail unloading facility within 150 feet of a number of very large refinery tanks that store highly flammable and potentially explosive material. If a derailment occurred at the terminal, it could set off a chain reaction of fire and explosions at the refinery. And there have been three derailments in Benicia outside the Valero refinery in the past year; luckily those trains were carrying petroleum coke, not crude oil.
Risk of Catastrophic Accidents All Along the Rail Route: Valero’s “Barkan report” that estimates a release only every 111 years from the proposed 100 daily tank cars carrying crude is absurd for many reasons. Most egregious is that it fails to consider recent data, like the six major crude oil train accidents over the past year that have resulted in massive fireballs and destruction, including 47 casualties in Lac Mégantic. The safety risks to tens of thousands of people living around these freight rail lines remains grave.
The oil industry has been promoting “look-alike” crudes that attempt to mimic conventional crude by blending extreme bottom of the barrel crudes. The mile-long trains laden with these extreme crudes are a Trojan horse that puts millions of Californians at risk and threatens to undo several decades of environmental progress. We need a moratorium on all new crude by rail projects, including Valero-Benicia, until the state can assess the cumulative impacts of these projects, make sure environmental impacts are fully mitigated and assure communities that they will be safe.
Check out these AMAZING critiques of Valero’s Draft EIR.
Here in Benicia on Friday, September 15, the final day of the public comment period, we congratulated Benicians For a Safe and Healthy Community’s DEIR subcommittee for their extraordinary effort – it’s long, but you have to at least scan through it a bit. Incredible detail and thoroughness, representing untold hours of expert volunteer labor!
If that wasn’t enough, as the day went by we were astounded when we received copies of critical comments from nearby environmental groups. In light of these studies, no one will be surprised if the City and Valero choose to re-write and recirculate the document. Some are saying Valero might simply withdraw the proposal. These highly technical reviews are overwhelming, and prove beyond a shadow of a doubt that Valero’s DEIR is fatally flawed. See below… (note: many of these are very large downloads – please be patient!)
A number of individuals also submitted comments and questions at the close of the comment period. These will be made available on our Project Review page when they are collated and published by the City.
Benicians for a Safe and Healthy Community submitted a 132-page letter to the City of Benicia on Monday, September 15, 2014, the final day to submit comments for the public record on Valero’s dangerous Crude By Rail proposal.
BENICIANS FOR A SAFE AND HEALTHY COMMUNITY RESPONSE TO DRAFT ENVIRONMENTAL IMPACT REPORT FOR VALERO BENICIA CRUDE BY RAIL PROJECT (SCH# 2013052074, USE PERMIT APPLICATION 12PLM-00063) Dated: September 15, 2014
Benicians For a Safe and Healthy Community (“BSHC“) respectfully submit this Response dated September 15, 2014 to the Draft Environmental Impact Report For Valero Benicia Crude By Rail Project (“Response“). Unless defined otherwise hereunder, capitalized terms and/acronyms used herein that are defined in the Draft Environmental Impact Report (“DEIR“) will have the meaning given to such terms in the DEIR. The Response includes this written response together will all prior oral and written comments to the DEIR provided by BSHS to date. BSHC would like to thank the many individual members of BSHC who contributed to this Response. Follow-up consultation with BSHC and the City of Benicia’s formal response to BSHC should be directed to Marilyn J. Bardet.
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