Sunday, September 29, 2013

further sulfur reductions now

In a recent application Valero used old (undated) modeling results for 24 hour sulfur dioxide concentrations but did not provide modeling for the one-hour SO2 health standard, which St. Bernard air quality is in violations of.  The 24 hour sulfur dioxide concentrations were listed as 321 ug/m3 SO2.  The AAS and NAAQS is 365 ug/m3 SO2.. very close to the 321 ug/m3.  LDEQ did not require Valero to model ANY emissions.

The people of St Bernard Parish deserve better.  When was the last time Valero did modeling for its Meraux refinery? Has modeling been done for the 2010 Sulfur Dioxide NAAQS at Valero? What are the results?

The modeling results information for PAH shows Valero is very close to violating the Annual AAS and NAAQS for PAH of 0.06 ug/m3; the result is 0.04 ug/m3.  How is that protective of human health? PAH have been identified as carcinogenic, mutagenic, and teratogenic.
Valero’s draft permit states after the Flare Gas Recovery System is completed the flare sulfur dioxide emission limits will change from the currently permitted level of just under 700 tons per year.  At that unknown time in the future, Valero proposes an updated annual sulfur dioxide emission cap of 182.5 tons per year SO2. Why not put in writing now a requirement to complete this FGRS much sooner?  Complete the FGRS before investing in other projects and expansions? That would be the best protection for our citizens and our community.  

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