United We Stand with Violet

 

In August 2021, the St. Bernard Parish Council voted unanimously to oppose Port NOLA's proposal in Violet, Louisiana. 

In December 2021, residents sued to preserve our community.

“Port NOLA is running roughshod over our community, completely disregarding the people who live here to force their massive container terminal on us,” said attorney Sidney Torres, III. “Literally millions of containers will be unloaded in our small town, destroying our way of life, endangering public health, damaging the environment, and decimating the economy.”

“Adding insult to injury is that there are more suitable locations that would make Louisiana more competitive, but these locations are being ignored because they fall outside of Port NOLA’s jurisdiction. It’s an age-old story of parochialism and greed, and it’s bad for the people of St. Bernard and the entire state,” he continued.

Read the law suit here

"Don't be surprised if this is the first you're heard of this. You might ask whatever happened to community engagement. Many people in St. Bernard are also just learning of the plan. Many did, however, turn out to convince the St. Bernard Parish Council to vote unanimously against this site." 

"One thing is clear. This is another time when New Orleans is serving as the canary in the mines. As infrastructure plans go forward across the country, communities will need to be vigilant to the possible community and destroying impacts if the planning does not respect them."     

The dark side of the coming infrastructure boom

By Jeanne Nathan, Crosstown Conversations N.E.W.S.

Chalmette Refinery Environmental Assessment

 

There are growing concerns for the human environment along East St Bernard Highway in the area of the bike shop, produce stand, school board building, the Paul Noel youths recreational gym, Baptist Church and day care, and residential neighborhoods across the street from the Chalmette east tank farm area.

When first public noticed, the Chalmette refinery's application for a Pretreatment Unit/Renewable Diesel Unit, which will produce renewable biodiesel from renewable feedstocks such as soybean oil, distillers corn oil, and other biogenically-derived fats and oils, it was purported to be colocated at the existing Chalmette refinery, to be within the existing refinery footprint. With restrictions on the zoning for the tank farm, many of us incorrectly assumed this meant all industrial type activity other than the tank farm would occur at 500 W St Bernard Hwy, where it would have a much larger set back, away from the community.  

With the very small space between the refinery and the community, every foot of separation makes a difference.

Although the diesel unit will be carved out from the existing hydrocracker unit at the refinery campus, it now seems probable that the pretreatment unit and feedstocks delivery and discarded wastes temporary storage may occur East of Paris Road on E St. Bernard Hwy. Currently, new tank storage at that location requires the local Council grant a conditional use to include requirements to protect the community's health and quality of life. Hopefully the PTU processing and feedstocks activity in that area will also require such protections.

At this time, there is not much public information towards odors, dust, particulate matter, and emissions from the pretreatment processes and activities. However benign the PTU emissions may be -compared to petro-chemical processing- these emissions will still affect public health, air quality and human lungs and respiratory systems. 

LDEQ is fully expected to require the Chalmette refinery resubmit a more transparent and complete application and associated environmental assessment survey. Public notice and public participation information, including online submission of comments, should become readily available on the State Agency website, and include links to both the draft air permit proposal and EAS.

Without a complete and transparent EAS, it has been difficult to understand the impact to public health, our children, neighborhoods, shops, schools, churches, day care, youth sports, and school board services in this area.

Public comments already submitted on this issue can be viewed in LDEQ EDMS.

Comments before public hearing

Interfaith Coalition for Climate Change https://edms.deq.louisiana.gov/app/doc/view?doc=12907056

Residents from various neighborhoods, Holy Cross Neighborhood, ByWater Neighborhood, Lower Ninth, Arabi 

  https://edms.deq.louisiana.gov/app/doc/view?doc=12911839

https://edms.deq.louisiana.gov/app/doc/view?doc=12911845

https://edms.deq.louisiana.gov/app/doc/view?doc=12920560

https://edms.deq.louisiana.gov/app/doc/view?doc=12914998

https://edms.deq.louisiana.gov/app/doc/view?doc=12920561

https://edms.deq.louisiana.gov/app/doc/view?doc=12917347

https://edms.deq.louisiana.gov/app/doc/view?doc=12974319

Comments at public hearing

Environmental Lawyer and Consultant from Baton Rouge, J O I N for clean air (Jefferson Orleans Irish Channel Neighborhoods for clean air), and Interfaith Coalition for Climate Change

https://edms.deq.louisiana.gov/app/doc/view?doc=13033840

Residents and above groups public hearing transcript

https://edms.deq.louisiana.gov/app/doc/view?doc=13032248

Other public comments

17 different residents from region  https://edms.deq.louisiana.gov/app/doc/view?doc=12993976

J O I N for clean air page 1, Resident page 106, Harahan / River Ridge group for air quality page 110, Concerned Citizens Around Murphy   page 113

https://edms.deq.louisiana.gov/app/doc/view?doc=12993977

sulfur dioxide non-attainment again

 

According to the Federal Registry The Environmental Protection Agency (EPA) is proposing to determine that the St. Bernard Parish sulfur dioxide (SO2) nonattainment area (“St. Bernard area” or “area”) failed to attain the primary 2010 one-hour SO2 national ambient air quality standard (NAAQS) under the Clean Air Act (CAA or the Act) by the applicable attainment date of October 4, 2018.

Submit public comments here on EPA's findings on sulfur dioxide concentrations in St Bernard Parish:

https://www.federalregister.gov/documents/2021/12/07/2021-26433/finding-of-failure-to-attain-the-primary-2010-one-hour-sulfur-dioxide-standard-for-the-st-bernard

Given the lack of space between the plants and the neighborhoods, EPA should require stricter measures for lower emissions at all sources of sulfur dioxide and particulate matter in St Bernard Parish. 

The combination of high PM and SO2 concentrations can be deadly. 

According to the University of Massachusetts Political Economy Research Institute tool:

 Chalmette Elementary, a school with 71% minority enrollment in St Bernard Parish, is in the 3rd percentile for air quality and Martin Luther King Charter school, a school with 100% minority enrollment in the Lower 9th Ward of Orleans Parish, is in the10th percentile for air quality. That's the environment the LDEQ and U S Senator Cassidy compromised when they convinced EPA to delay enforcement action. That's the environment the LDEQ and Senator Cassidy provided for our school children; that environment is in the 97% and 90% percentiles for WORSE air quality in our nation. 

Its past time for EPA to step in and step it up.

The neighborhoods near Rain Carbon CII and PBF Energy's Chalmette Refining LLC are exposed to large amounts of particulate matter and according to the EPA EJSCREEN Map Tool, some neighborhoods are in the 95 to 100% National and State percentile NATA diesel particulate matter.

EPA should protect what good air is left in our communities and conduct both a human health risk assessment and a cumulative impact analysis for the human environments within ten miles of each site of heavy industry in St Bernard Parish; not just for sulfur dioxide, but for all emissions. EPA should consider in St Bernard Parish delay of issuance of all Title V air permits (initial, renewal, and or modification) until the analyses data are reviewed and required improvements incorporated in the air permits. 

Given the numerous health and odor complaints from residents in Lower Algiers, Holy Cross, and Lower Ninth Ward neighborhoods in New Orleans, EPA should also consider that the SO2 attainment modeling data will and should designate Orleans Parish non-attainment for the one-hour health standard for SO2. Without such designations, LDEQ will not require lower emissions. The LDEQ air quality monitor network is not robust and has only 29 monitors for the entire State. EPA should consider this lack of appropriate monitoring does not prove an exceedance of the air standard can not occur. EPA should at least consider requiring LDEQ re-install the previous "Entergy" site air monitor in Lower Algiers New Orleans, across the river from Chalmette, and the previous "Arabi site air monitor or a new site monitor in the Holy Cross or Lower Ninth Ward neighborhoods.

EPA should also consider air modeling will and should designate St Bernard Parish non-attainment for particulate matter PM10 and PM2.5 levels.

Innovations in control technology business practices are always evolving and improving and have proven protective of public health and air quality. EPA should require implementation of the best technologies and business practices in both St Bernard and Orleans Parishes. EPA should require LDEQ update its State Ambient Air Standards [AAS] for air toxins, as standards should be reviewed periodically and improved as technology and best business practices improve. When was the last time Louisiana reviewed and improved its air standards?

When EPA conducts these air modeling dispersion studies, all sources should be included. Since the last time St Bernard Parish was designated non-attainment for the one-hour health standard for sulfur dioxide, major sources have re-started previously idled units, which were not likely included in the Louisiana SIP (state implementation plan) to improve air quality. One example is the additional coker unit at PBF Energy's Chalmette Refining LLC which restarted in 2018 for the first time in nine years. PBF Energy's Chalmette Refining LLC recently applied for an initial Title V Part 70 operating air permit for a proposed renewable diesel unit, and citizens who participated in the public comment opportunity for the renewable diesel unit found the application lacked modeling data, and the EAS to be insufficient, incomplete, and not even included in the LDEQ public notice link. [1]

Submit public comments here on EPA's findings on sulfur dioxide concentrations in St Bernard Parish:

https://www.federalregister.gov/documents/2021/12/07/2021-26433/finding-of-failure-to-attain-the-primary-2010-one-hour-sulfur-dioxide-standard-for-the-st-bernard

[1] https://edms.deq.louisiana.gov/app/doc/view?doc=13032248

https://edms.deq.louisiana.gov/app/doc/view?doc=12993977

school children harmed by air quality

 

From cancer alley to diesel death zones, land use decisions in Louisiana fail to protect the human habitat

Chalmette Elementary school is in the third percentile worse air quality in the States; Martin Luther King Charter school in the Lower 9th Ward is in the tenth percentile worse air quality in the States

No industry No economic development is worth human lives

It seems the Louisiana Department of Environmental Quality and U S Senator Cassidy are not interested in protecting the human environment in Chalmette and Lower 9th ward and Lower Algiers.

Rain Carbon CII operated for years, spewing out sulfur dioxide in quantities so large that when combined with the emissions from other plants, the air quality in St Bernard Parish violates the one-hour health standard for sulfur dioxide. Rain CII acknowledged it was the source of the "lion's share of emissions." St Bernard Parish was designated non-attainment for sulfur dioxide and the State of Louisiana was finally required to ratchet down emissions through a “state implementation plan” which required all major sources of sulfur dioxide install more stringent control technologies and change processes to improve air quality.  https://www.regulations.gov/document/EPA-R06-OAR-2017-0558-0038

"Rain balked, however, saying it was having trouble figuring out how to monitor the heat and flow of gases and other materials at its plant because conventional meters kept melting. In 2019, U.S. Sen. Bill Cassidy, R-La., intervened on behalf of the company and joined the state agency in successfully lobbying the EPA to delay implementation of the plan." NOLA Environmental News Tristan Baurick

The way the community concerns are ""addressed"" is a promise to reduce emissions and install pollution controls, and yet it never seems to happen

It's past time for the EPA to step in

EPA proposes to yet again designate St Bernard Parish air quality non-attainment for the one-hour health standard for sulfur dioxide.

Public comments can be made at https://www.federalregister.gov/documents/2021/12/07/2021-26433/finding-of-failure-to-attain-the-primary-2010-one-hour-sulfur-dioxide-standard-for-the-st-bernard

Comments must be received on or before January 6, 2022.

Submit your comments, identified by Docket No. EPA-R06-OAR-2017-0558, at https://www.regulations.gov. 

Public comments submitted here:      https://www.federalregister.gov/documents/2021/12/07/2021-26433/finding-of-failure-to-attain-the-primary-2010-one-hour-sulfur-dioxide-standard-for-the-st-bernard#open-comment

Let's Clear the Air

 

This Chalmette plant has been spewing sulphur dioxide for years; now EPA is taking action.

U.S. Sen. Bill Cassidy intervened for company in 2019, delaying federal enforcement

• BY TRISTAN BAURICK | STAFF WRITER
 
• DEC 13, 2021
• • NOLA News Environmental
    

"The persistence of toxic emissions from the [Rain Carbon CII petroleum coke calcining] plant, eight years after it admitted fault, illustrates the slow pace of enforcement in a state with long history of relying on industry for jobs and tax revenue." -- Tristan Baurick

In addition to an unacceptable slow pace of environmental protection for air quality, the exposed communities are further harmed with even more particulate matter when this plant is granted permit variances. Sulfur and particulate matter emissions combine and become even more harmful for those of us who breathe with lungs. Particulate matter PM2.5 and sulfur dioxide commonly co-exist in the atmospheric environment, and epidemiological studies have linked air pollution to the development of neurodegenerative disorders, in addition to increased morbidity from cardiopulmonary diseases. These are diseases the LDEQ and EPA could be protecting us from.

Rain CII Carbon is a petroleum coke calciner, located adjacent to the PBF Energy Chalmette refinery (former Tenneco). Rain CII seems challenged to achieve its Title V permit limits and its State implement plans (SIP). Rain CII operates on a permit which seems to have a permanent variance of 500 annual operating hours for bypasses of the steam boiler and baghouse that allows the pyro-scrubber to vent directly to the atmosphere; this direct venting often appearing as a purple colored discharge. LDEQ still renews the variance and grants additional variance operating hours, often without public notice. 

Post Hurricane Ida August 2021, LDEQ granted Rain CII a 30 day permit variance for 720 additional bypass hours with additional particulate matter emissions at 23.80 tons PM10 and 22.85 tons PM2.5. According to the variance, Rain CII reported: Due to Hurricane Ida, Rain sustained significant roof damage to building that houses the steam turbine, and the plant was without power. As such, Rain could not utilize the energy side of the plant, which includes the waste heat boiler. To operate the plant, Rain needed to vent from the Pyroscrubber Stack until damages repaired. If not granted this variance, Rain pleaded the forced shutdown for an extended period of time to repair damages would lead to severe economic hardship. LDEQ granted this permit.

Now in November, Rain CII again applies for a permit variance for 720 additional bypass hours for 30 days in the beginning of next year, 2022; if granted, this variance will also result in additional particulate matter emissions. According to the application, Rain CII reported it needed to make extensive repairs to its waste Heat Boiler. The boiler repairs will coincide with a scheduled plant turnaround but will take an additional four weeks to complete. If the Hot Stack cannot be utilized during this repair time then Rain will be forced to shutdown for an extended period of time, which will lead to severe economic hardship on Rain.

Rather than protect public health and require industry to make repairs and conduct turnarounds without bypassing pollution controls, the LDEQ further burdens the surrounding communities. 

EPA needs to step in and step it up.

Rain CII Carbon variance LDEQ EDMS document 12891265 dated September 9 2021 https://edms.deq.louisiana.gov/app/doc/view?doc=12891265

Rain CII Carbon variance application LDEQ EDMS document dated November 16 2021   https://edms.deq.louisiana.gov/app/doc/view?doc=13008218

Louisiana Redistricting Meetings

 

State Legislature website for redistricting criteria, 2020 Census maps and reports, and list of state-wide meetings.

https://redist.legis.la.gov/

January 5 2022  5:30 - 8:30pm University Center UNO, New Orleans

 The legislature seeks active and informed public participation in all of its redistricting activities. The legislature intends to provide for the widest range of public information about its deliberations and full opportunity for citizens to make suggestions and recommendations to the legislature, all in accordance with the rules and policies of each house of the legislature and the provisions of law relative to open meetings and public records.

St Bernard Parish Census data