The Benicia Independent is in receipt of a very important letter sent to the City of Benicia Planning Commission on February 8, 2016 by the Bay Area Air Quality Management District (BAAQMD).
Commissioner Steve Young read from the letter at Monday’s Planning Commission meeting. City staff posted this important letter online yesterday, but located it on page 26 of a 256-page, 14 MB document of public comments received after the release of the FEIR (Jan. 28 – Feb. 8). The letter is available as a standalone PDF document here on the Benicia Independent.
The letter states that the Final EIR is inadequate, and gives examples of air quality mitigations that do not conflict with federal preemption.
The letter goes on to point out that air quality studies in the FEIR rely on inaccurate and outdated risk analyses.
The BAAQMD offers in the letter (again) to assist Benicia and Valero in developing and implementing appropriate mitigation measures.
Benicia: Valero to pay $196,000 to settle air quality violation notices
By Tom Lochner, 10/29/2015 04:35:26 PM PDT
BENICIA — Valero Oil Co. will pay $196,000 for air quality violations at its Benicia refinery, the Bay Area Air Quality Management District announced Thursday.
The settlement covers 23 violation notices issued by the air district for incidents that occurred in 2012, the district said. The two most significant ones involved errors in an inspection database that omitted listing certain valves, resulting in missed leak inspections.
Eight of the lesser violations involved excessive emissions measured by monitors; six involved hydrocarbon vapor leaks from valves or seals on storage tanks; and seven involved late reports or other minor administrative violations. All were corrected as soon as they were discovered, the district said.
The air district is proposing four new rules that would require tougher emissions limits, more monitoring, and quicker equipment repairs and upgrades to help meet its 20 percent refinery emissions reduction goal by 2020.
Benicia Resident Marilyn Bardet’s letter to the Chair of the Board, Bay Area Air Quality Management District (BAAQMD)
Direct staff to require numerical emissions caps on all refinery emissons
By Marilyn Bardet, Sept 16, 2015
Dear Chair Groom,
Marilyn Bardet, Benicia CA
In response to the overwhelming testimony the District has received from all corners of the Bay Area, as chair of the BAAQMD board of directors, you, with your board, have the authority to direct District staff to revise DRAFT Rules 12-15 and 12-16 as currently released, to require strict numerical emissions caps on all refinery emissions, including GHG.
By all means of public testimony over a two-year period, you have heard from concerned and affected members of the public, respected regional and national organizations (including Sierra Club, NRDC, CBE, 350 Bay Area, APEN, Sunflower Alliance) and other experts in the field who have recommended and put forward well-defined revisions that would impose strict numerical emissions caps on refinery emissions tied to current emissions baselines for TAC, VOCs, heavy metals and PM2.5, including GHG.
You know that oil companies in the region aim to acquire and process the most dangerously polluting crude in the world — tar sands. Refineries processing changed crude slates whose blends have increasing amounts of heavy crude, unconventional crudes such as Bakken oil, and/or tar sands will adversely impact regional and local air quality, especially affecting front-line communities and those “downwind communities.” Allowing emissions to “go up to” long ago established permitting levels (Valero Benicia’s permit was established in 2003) is tantamount to the District “giving in” to benefit the oil industries’ profit, not public health.
The District’s mandate is to clean up the air for the benefit of public health, and, in accordance with state mandates, to protect the climate by drastically reducing GHG. Oil refining is the biggest industrial source of GHG. Carbon trading by refineries will simply send “pollution credits” elsewhere and keep toxic emissions “at home” that kill thousands of people in the Bay Area each year. GHG emissions from fossil fuel combustion threaten to destroy our global climate and way of life.
Strong refinery rules that set numerical limits on toxic emissions tied to current baselines and limit GHGs are our best chance to protect public health and protect the climate.
We need your leadership more than ever now! I am writing to ask that you make it clear to your directors that the “highest good” must be done by BAAQMD in the name of public health and climate protection, such that, until revisions to Rules 12-15 and 12-16 are adopted that set refinery emission caps at today’s levels, including for GHG, the agency will suspend permitting for refinery projects.
This is a bold request, but these are very uncertain times that require every precaution and concerted action by leadership to create policies that protect people and the planet.
Thank you for your public service, and for you attention to my comments.
Air District to have 2-hour ‘open house’ at Robert Semple Elementary on Sept. 17
Debate over the Valero Crude-by-Rail Project — now well into its third year — intensified last week after the release of the revised Draft Environmental Impact Report. But even as residents, businesses and others in the city continue to pore over that massive document, they will have the opportunity to learn more about newly drafted state rules for refineries at a forum here next week.
The Bay Area Air Quality Management District will host a series of open houses at elementary schools in the refinery-heavy nexus of Benicia, Martinez and Richmond this month to present the agency’s four new and amended rules to reduce refinery emissions.
“This is part of an effort to reduce emissions from Bay Area refineries by 20 percent or as much as feasible by 2020,” Air District spokesperson Ralph Borrmann said Friday.
The four rules deal with limiting ammonia from fluid catalytic cracking units; broadening equipment leak standards to include all equipment that handles heavy liquids; reducing sulfur dioxide from coke calcining processes; and regulating cooling towers to reduce emissions of organic compounds, toxics and methane by being able to detect and fix leaks.
“The Air District passed a resolution almost a year ago to develop a strategy to reduce refinery emissions,” Borrmann said. “Bay Area refineries are among the most regulated in the country, if not the world, but these meetings are presenting the public with an ambitious approach to reduce emissions that are part of an aggressive approach to regulate refineries in our area.”
The open houses, Borrmann said, will not be lectures but rather forums for people to discuss and gather information. Tables will be set up with in-house experts so attendees can ask questions about the new rules, he said.
“We hope the communities and other stakeholders will have an opportunity to learn about air quality and have a role in the rule-making process,” he said.
The BAAQMD’s Benicia open house will be from 6-8 p.m. Sept. 17 at Robert Semple Elementary, 2015 East Third St.
The two other open houses will be Sept. 15 from 6-8 p.m. at Las Juntas Elementary School, 4105 Pacheco Blvd., in Martinez; and Sept. 28 from 6-8 p.m. at Lincoln Elementary School, 29 Sixth St., in Richmond.
The Benicia Independent is in receipt of a very important letter sent to the City of Benicia Planning Commission on February 8, 2016 by the Bay Area Air Quality Management District (BAAQMD).
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