Category Archives: Toxic pollutants

Emissions are way down. No, that’s not all good news for the environment.

Chaos in the oil sector could actually intensify climate change.

Mother Jones, by Rebecca Leber, April 21, 2020
Getty

As the coronavirus cripples world economies, greenhouse gas emissions are plummeting: This year, they could drop by as much as 5.5 percent—the largest decrease ever recorded. On Monday, the price of oil went negative, meaning storing oil now costs more than the oil itself. Since we’re burning less gas and fuel, air pollution has dropped 30 percent in northeastern cities, and Los Angeles’ notorious smoggy skyline has cleared.

You might be thinking all this is great news for the environment. It’s a nice idea—but the real story is more complicated. “You don’t want companies collapsing like this,” says Andrew Logan, oil and gas director of Ceres, a think tank focused on sustainable investment. “Even the most ardent climate advocate shouldn’t wish for a chaotic transition in this sector. A chaotic transition brings all sort of pain to workers and also the environment.”

It helps to think of COVID-19 as a test run—a very painful one—of what an industry in decline will look like. “We’re seeing, as is case the now, what the cliff looks like if everyone shuts down at the same time,” Logan says.

With a glut of supply, North America producers Exxon, Shell, Devon Energy, and Cenovus Energy have already collectively announced spending cuts this year totaling $50 billion, according to the Wall Street Journal. In North Dakota, Trump donor Harold Hamm’s Continental Resources drilling company has cut output by 30 percent the next two months. In Canada, the famously destructive tar sands are too expensive to mine and refine on oil prices this cheap. Even the Southwest’s Permian Basin, the most productive region for oil and gas in the United States, is expected to see dramatic closures.

Environmentalists are worried about what comes next, because of the many unintended consequences of market chaos. For starters, when gas prices tank, Americans will likely start buying more cars and taking more road trips, driving up demand all over again.

Other environmental problems aren’t quite so obvious. Lorne Stockman, a senior research analyst with the climate advocacy group Oil Change International, worries that the coming bankruptcies this year “are an environmental nightmare in the making,” with “wells left to rot as bankruptcy proceedings are going through.”

As the industry contracts, some drilling operations will simply leave their wells, and many don’t have the funding set aside to take proper precautions to make sure greenhouse gases and other pollutants don’t leak out. Environmental advocates are especially worried about leaks of methane, a particularly potent greenhouse gas.

Abandoned wells are already a big problem. Even in relatively good times, oil and gas wells still dry up. When they do, they might be sold to smaller, sometimes less scrupulous operators to tap what’s left in the well. Then those operators eventually abandon the well or go bankrupt. They can’t afford to clean up the site, which involves plugging the well with cement to avoid leaks into groundwater.

We don’t know for sure how many of these wells exist around the country, though the EPA estimates there are more than 1.5 million of them that have accumulated over a century. Wyoming has had thousands it’s in the process of plugging, and Pennsylvania has 8,000. Taxpayers will eventually pay for both cleanup and environmental damages.

Drilling operations that don’t shutter will have to find ways to cut costs. In boom times, methane is valuable to drillers because it can be captured and reused for fuel. But when oil and natural gas prices have crashed in the past, drillers have sought to get rid of excess methane in the cheapest way possible—by burning it (a process known as “flaring”) or simply letting it leak into the atmosphere (called “venting”). Both processes can contribute to climate change and contaminate surrounding communities. Flaring and venting worry many environmental advocates. The International Energy Agency notes that “low natural gas prices may lead to increases in flaring or venting, and regulatory oversight of oil and gas operations could be scaled back.”

Methane emissions hit a 20-year high last year, according to the National Oceanic and Atmospheric Administration. Although scientists don’t fully understand why, they believe that fracking operations may dramatically underestimate the methane they release. According to the Environmental Defense Fund, operations typically lose 15 times the rate that producers report because of malfunctions and intentional venting. The COVID-19 crisis could lead to more leaks, because companies won’t have any incentive to capture methane to use for fuel.

Amid the turbulence in the oil sector, the Trump administration has continued to roll back environmental regulations, and it has already undone Obama-era rules targeting methane emissions from oil and gas operations.

Nathalie Eddy, a field advocate for the environmental watchdog Earthworks, is worried that environmental contamination will be made worse as the administration weakens rules. “When the market falls like this one of the first things that will go is the limited capacity for inspection,” she says. The EPA, Department of the Interior, and Department of Transportation have already announced they will suspend some routine inspections and monitoring, including pipeline reporting and field inspections, and waive civil penalties if violators say COVID-19 was a factor.

Climate advocates have urged the EPA and Department of the Interior to require companies to monitor methane leaks and set aside money for their cleanup. To help the sector recoup the lost revenue, they propose a job stimulus program aimed at reclaiming these sites for the double-duty benefit of a clean environment and keeping workers employed.

But so far, those pleas are going unanswered. The Trump administration has floated several schemes for helping the oil sector: During the first round of stimulus, congressional Democrats managed to shoot down the oil industry’s bailout request. Now, the administration is considering paying producers to leave crude in the ground until the global glut shrinks. Meanwhile, the major banks want some collateral for the $200 billion they are owed from oil companies: According to Reuters, JPMorgan Chase, Wells Fargo, Bank of America, and Citigroup could even seize the industry’s assets, which could pose an enormous conflict of interest for a financial sector that just months ago was signaling a move away from the oil sector.

So far, it looks like the short-term emissions drop won’t result in any lasting policy improvements, Stockman says. “We have seen the wrong kind of stimulus that isn’t aimed at changing our relationship to fossil fuels.”

What Just Happened to the Mercury Rule?

Energy Institute Blog, by Meredith Fowlie, April 20, 2020

Last week’s EPA decision adds insult to injury for our already vulnerable communities.

Perhaps you missed it. There’s a lot going on right now. But amidst all the COVID-19 headlines last week, the EPA decided that it is not “appropriate and necessary” for the government to limit emissions of mercury and other hazardous air pollutants from power plants.

coal
Source: Pixabay

This is not a roll-back of a regulation. It’s more nuanced than that. It’s a high-stakes procedural move with two important implications:

First, it scraps the legal basis for the Mercury and Air Toxics Standards (MATS) which limit hazardous air pollution from coal and oil-fired power plants. Having knocked the legal foundations out from under this important regulation, I think there’s a real risk that power plants will find ways to dial back on compliance in the future.

Second, it sets a dangerous precedent for how the benefits and costs of federal environmental regulations are assessed. The ruling removes significant health benefits from cost-benefit consideration on the grounds that they are not directly targeted by MATS.

This announcement comes at a time when the country is reeling from the global coronavirus pandemic. Protecting public health is top of mind. We’ve all become keenly aware of how actions we take can indirectly protect the health of the most vulnerable among us. With these benefits in mind, we are taking action.

Meanwhile, the EPA has decided that the indirect health benefits of pollution reductions should not be considered in regulatory cost-benefit analysis. This decision departs recklessly from standard practices for responsible public decision-making.

Some colleagues and I recently published this paper (based on our longer report) which points out deep flaws in this EPA decision. The agency’s own Science Advisory Board released a report calling for a “do-over”. Hundreds of thousands of public comments raise concerns. Even the electricity sector stands in opposition. The Trump EPA response: To hell with it. We are pushing ahead.

To understand what this means, we need to remember how we got here.

The Mercury and Air Toxics Standards limits the emissions of mercury and other hazardous air pollutants (HAPs) from power plants. To justify the rule, the EPA must demonstrate that it is appropriate and necessary. Back in 2011, the EPA supported this argument with a detailed analysis that projected big public health benefits from the power plant emissions reductions expected under the regulation. The table below, taken from the 2011 analysis, shows monetized benefits far exceeding the costs.

table
Summary of the quantified benefits and costs in the 2011 RIA for the MATS rule. These are projected for the year 2016. The data reported in this table are from Table ES-1 of EPA (2011).

There were some serious bumps on the road to implementation. But power plants began complying in 2016. The industry has since invested billions to install pollution abatement equipment in order to meet MATS requirements.

Last year, the Trump EPA started working to reverse the appropriate and necessary finding. The agency issued this six-page memo that re-interprets the 2011 cost-benefit analysis. There’s no new information here. The big change is that the “co-benefits” – health benefits that result indirectly from MATS compliance—have been wiped off the cost-benefit board. If we ignore these benefits (row 3 in the table above), MATS appears to fail the cost-benefit test.

There are many reasons to be concerned about this maneuver.  Let me unpack three:

  1. Co-benefits are real benefits

When power plants reduce mercury emissions, they also reduce emissions of precursors to harmful particulate matter (PM). Reducing exposure to small particulates saves lives. These benefits are referred to as “co-benefits” because they are caused by – but not directly targeted by – the regulation.

If a policy will generate big health benefits, directly or indirectly, these should be counted. Federal agencies are under Executive Order to weigh the available evidence on all significant costs and benefits in their regulatory assessments. This is also required under the EPA’s own guidelines for economic analysis.

An official decision that eliminates or reduces consideration of co-benefits sets a troubling precedent for future regulatory decisions. If this approach becomes standard, it becomes much more difficult for the EPA to justify socially beneficial regulations. Greenhouse gas emissions regulations- which can deliver significant reductions in local air pollution- are one important example.

  1. Direct benefits estimates are outdated and incomplete

The 2011 direct benefit projections that serve as a basis for last week’s decision reflect only one health benefit from reducing mercury emissions: improvements in the IQs of children whose families catch and eat freshwater fish. This narrow focus explains why those 2011 direct benefits estimates are so small.

A decade later, we know a lot more about how power-plant mercury accumulates in commercial seafood consumed by many Americans. In addition, recent research suggests that mercury exposure could cause cardiovascular problems. If these additional health impacts were accounted for, the direct benefits of HAP reductions would look quite different. But the 2020 EPA decision is still referencing outdated and incomplete 2011 benefits numbers.

  1. Costs are largely in the past

To comply with MATS, billions have been invested in equipment that scrubs harmful pollution out of power plant emissions. In other words, the investment costs that comprise the majority of the 2011 cost projections have already been incurred. Going forward, the costs we need to consider are the costs of operating this pollution abatement equipment. Estimates I’ve seen range from  $1.80/MWh to as high as $7.92/MWh (a non-trivial increase in coal-fired electricity generation costs).

FGD
Flue gas desulfurization is one of the technologies used to comply with MATS (Source)

By dismissing the legal basis for the rule, MATS is left wide open to the challenge that the pollution controls are no longer legally required. If I were a coal plant operator, I might read between the lines of this decision and conclude that the EPA is not so concerned about enforcing MATS going forward.

Coal plants across the U.S. are struggling to compete with natural gas and renewables. If MATS requirements are not there to keep pollution controls switched on, plants in competitive electricity markets will have an incentive to turn this equipment off to save a few dollars/MWh. If this happens, downwind communities will pay a hefty health price.

Adding insult to injury

You would think that a high-stakes regulatory decision like this would merit an analysis update given that almost a decade has passed since the original assessment was done. The reams of data and scientific evidence that have accumulated since 2011 could provide a much more accurate evaluation of the rule’s benefits and costs, in addition to a more informed basis for re-evaluating the appropriate and necessary finding.  Instead, this EPA has dusted off a stale 2011 analysis, deleted the co-benefits, and declared the rule unnecessary and/or inappropriate.

The timing of this decision feels particularly callous because the communities that have historically been most exposed to high levels of air pollution are the ones being hit hardest by the COVID-19 crisis. This recent study suggests that even small increases in long-term exposure to particulate matter significantly increase COVID-19 fatality risk.

The Trump administration assures us it is putting “safety first” during this COVID-19 epidemic. But in the background, Trump appointees have been doing quite the opposite with decision after decision after decision. This MATS reversal has the potential to do real damage. But if there is good news to be found in this story, it’s that it will take time to play out. One more reason to work hard to course correct in November.

Keep up with Energy Institute blogs, research, and events on Twitter @energyathaas

Suggested citation: Fowlie, Meredith. “What Just Happened to the Mercury Rule?” Energy Institute Blog, UC Berkeley, April 20, 2020, https://energyathaas.wordpress.com/2020/04/20/what-just-happened-to-the-mercury-rule/

Valero emissions alerts – personal update with photos from Marilyn Bardet

An email from Marilyn Bardet, Benicia

From: Marilyn Bardet
Subject: About Solano ALERT notice: Valero’s Scrubber releasing toxic particulate matter–pet coke
Date: March 24, 2019 at 8:16:22 AM PDT

Good morning all,

I just received both a phone call and email from Solano ALERT at 6:59 a.m. regarding the ongoing problem at the refinery that’s resulting in continuous release of PM from the Scrubber, (main stack). I see emails circulating now among Benicians— and so you’ve all probably rec’d the advisory by now to “stay indoors, with doors and windows sealed, if you have asthma or other respiratory condition”. The advisory declares that they’ve tested the pet coke emissions and did not find (dangerous levels) of heavy metals. (Which is not to say there are no heavy metals being dispersed over the last ten days).

My concern:
This problem has been happening since at least March 13th, when I first saw the plume, having been alerted by a friend who had called to report its smokey color.  That day, following her phone call, I drove along  Park Road and Industrial Way (east of the refinery’s processing block) to see it for myself and take pictures.

The release of dark smoke from the Scrubber signals an “up stream” on-going problem with the coker unit. My question: is the coker still operating or has it been shut down? If it’s not operating, when was the unit shut down?

Yesterday, I was driving over the Benicia Bridge toward town and saw the plume and again noticed the smokey color, so went directly to Industrial Way to take pictures. I made a 1 minute video, holding my camera outside my car window to get it. This meant that I could see and smell the smoke— a very dirty, nasty smell. Anyone working in the Industrial Park yesterday downwind of the Scrubber  would have been greatly exposed.  I could smell the gases inside my car when I rolled up the window.

You’ll notice that in the still shots from yesterday, the plume rises, drifts and falls. . . the wind was light, the molecules heavy!

I can’t send the video via email, because the file is too large, but Constance will be able to circulate it.

I want to know about the test for heavy metals and which ones they did find and in what concentrations. Was there any nickel found? Nickel is a known carcinogen when inhaled.

All it would take would be a shift in the wind to bring the PM into our neighborhoods.

— Marilyn

The following pictures I took on March 13th,  between 11:33 a.m. and 11:35 a.m (click to enlarge):

The following pictures I took on March 23, at 2:21 pm
(click to enlarge):

Attorney General letter may be terminal for ORCEM / Vallejo Marine Terminal

By Roger Straw, November 30, 2018
Nov. 7 2018 letter from Deputy Attorney General Erin Ganahl

Take heart, Vallejoans!  The letter sent to your City by the Attorney General may just do the trick.  (See Times-Herald Nov. 12 coverage.)

I remember back in Benicia’s crude-by-rail days, when Deputy Attorney General Scott Lichtig of Attorney General Kamala Harris’ staff wrote to the City of Benicia.  He wrote first in 2014 urging revision of an “inadequate”  Draft EIR, and again in 2016, defending the City’s right to deny a land use permit.  Lichtig advised our city leaders, “For Benicia to turn a blind eye to the most serious of the Project’s environmental impacts, merely because they flow from federally-regulated rail operations, would be contrary to both state and federal law.”

There were a LOT of us who worked long and hard to defeat Valero’s dangerous and dirty oil train proposal.  Local activists and folks from far and wide disagreed with City staff and Valero’s execs and highly paid attorneys.  We criticized, protested and sent volumes of comments over the course of 3 ½ years.  Scientific and environmental experts and friendly attorneys weighed in.  But it was eye-opening for everyone when the Attorney General’s office got involved.

But… note that the AG letter wasn’t enough.  It’s important here for us to not dwell on the past or get too optimistic.  Stay tuned via Fresh Air Vallejo and keep up the good work.

…because ORCEM/VMT wants to run 552 trucks a day up and down Lemon Street!  We stand in solidarity with residents, business owners and all of our neighbors in Vallejo.  And it’s important to realize that the truck exhaust will travel by air west to east, settling, surely, in Glen Cove and Benicia.

Let’s hope the Vallejo City Council has the backbone Benicia had in 2016, to DENY THIS PROPOSED CATASTROPHIC PROJECT!