St Bernard, our roots run deep

 

Documentary Isleños, a Root of America

This incredible adventure began two hundred years ago with the arrival of 2,500 Canaries in Louisiana to defend the territories of the Spanish Crown against the English and has continued to the present day where we find the Canarian traditions, speech, gastronomy and idiosyncrasies present in a community, proud of their origins and in a constant struggle not to succumb to oblivion

http://lagavetaproducciones.com/portfolio/documental-islenhos-a-root-of-america/

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We all need to do our part to be part of the solution

 

PBF Energy's Chalmette location affect on local air quality for sulfur dioxide concentrations

St Bernard Parish air quality is non-attainment for the one-hour health standard for Sulfur Dioxide. 

The concentrations of sulfur dioxide in the air we are forced to breathe are too high. Based on information in EPA's final rule and recent proposed Settlement Agreement between PBF Energy and LDEQ, it is highly likely PBF Energy's Chalmette location contributed its fair share to the non-attainment status.

There are numerous permit violations from 2015 - 2019 noted in the PBF Energy - LDEQ proposed Settlement Agreement. A number of the permit violations involve excess emissions of Sulfur Dioxide, and some of the SO2 emissions are reported -- not in pounds but -- in Tons. 

PBF Energy included reports of:

3.6 Tons (7200 pounds) SO2 over 5 hours

3.7 Tons (7400 pounds) SO2 within one hour and a half

0.41 Tons (820 pounds) SO2 in less than 2 hours

3997 pounds (nearly 2 Tons) SO2 in less than 30 minutes 

1665 pounds (0.83+ Tons) SO2 within 17 minutes

9072 pounds (4.5+ Tons) SO2 over more than 7 hours

PBF Energy noted each of these above incidents as "preventable". 

Each of these would be expected to result in higher concentrations of Sulfur Dioxide than were accounted for or modeled for by Louisiana's State DEQ plan to achieve attainment. It is easy to understand that just a few of the SO2 permit violations at PBF Energy's Chalmette location likely resulted in exceedances of the one-hour SO2 NAAQS.  

Since the 1-hour SO2 NAAQS is an hourly standard that is based on the three-year average of the 99th percentile of the annual distribution of daily maximum one-hour average concentrations, the potential exists to violate the standard with relatively few modeled or monitored exceedances. The numerous permit violations at PBF Energy's Chalmette location likely contributed more than just a few.

PBF Energy completed its $322 Million purchase of the Chalmette refinery and associated assets in early 2015. 

In its first 7 years, it seems PBF Energy has much room for improvements. 

PBF Energy needs to step it up, do its part to be part of the solution, and make a commitment to its daily operations that demonstrate respect for the people who reside on the other side of the fence. 

For decades Chalmette, Arabi, Lower Algiers, and Lower Nine neighbors have suffered the ill health effects of emissions from industry in St Bernard Parish Louisiana and residents and visitors alike have documented the associated obnoxious odors. 

In the proposed Settlement Agreement between PBF Energy and LDEQ, some of the enforcement orders are for "potential odor issues" under Louisiana administrative code LAC 33 III 2901 Odorous Substances. The purpose of Louisiana odor regulations is to establish an ambient air standard for odors and to prohibit or limit odorous substances at or beyond the sources property line.

Clearly, industry in St Bernard Parish has failed to comply with Louisiana's odor regulations.

Enforcement orders and other information in the proposed Settlement Agreement between PBF Energy and LDEQ indicate the below listed permit violations.

The public is invited and encouraged to submit public comments and request for public hearings to LDEQ via   deq.publicnotices@la.gov

REFERENCE:  Settlement Tracking Number:  SA AE 22 0024 AI 1376

Enforcement AE-PP-19-00542

1. An April 13 2019 preventable occurrence at the aromatics cooling water unit where relief valve(s) released 6.7 Tons VOCs (13,400 pounds VOCs) and 53.8 pounds benzene to the atmosphere.

2. A February 27 2019 preventable occurrence during a power outage where affected units released material high in Hydrogen Sulfide content to the flares resulting in SO2 emissions in excess of the permit limits. Flaring of about 5 hours resulted in the release of 3.6 Tons SO2 (7200 pounds SO2 over 5 hours).

3. Also during the February 2019 power outage a hose in the diesel fuel system to the cooling power pump engine developed a leak and ignited. 

4. A July 26 2018 preventable incident with the process gas compressor of the FCCU resulted in 81 minutes of intermittent flaring that released 3.7 Tons SO2 (7400 pounds SO2 in less than one and a half hour) and 2.8 Tons VOCs (5600 pounds VOCs)

Enforcement AE-PP-18-00720

1. A March 16 2018 preventable incident with the FGR compressor resulted in 113 minutes intermittent flaring that released 0.41 Tons SO2 (820 pounds SO2). The permit limit for that flare was noted as 101.38 pounds per hour. The release was approximately 820 pounds for nearly 2 hours, or over 400 pounds per hour, which is 4 times the permitted level.

Enforcement #AE-CN-17-00789

1. A June 29 2017 preventable incident when the # 2 Coker wet gas compressor inadvertently shutdown resulting in flaring for 29 minutes releasing 3997 pounds of Sulfur Dioxide.

2. A June and July 2017 Full Compliance Evaluation inspection revealed PBF Energy's Chalmette refinery failed to conduct the required stack testing for a waste (sic) gas compressor #3 in order to demonstrate compliance with its air permits.

3. An April 13 2017 incident during a restart from a March 3 2017 preventable incident. The restart incident resulted in 17 minutes of intermittent flaring releasing 1665 pounds Sulfur Dioxide

4. A March 3 2017 preventable incident for the # 2 Coker resulting in 431 minutes (over 7 hours) of intermittent flaring releasing 9072 pounds Sulfur Dioxide.

5. A January 17 2017 preventable incident of the aromatics unit releasing 50 barrels of Suloflane, 760 pounds VOCs, 400 pounds benzene, and 60 pounds xylene

6. A September 2018 file review to determine compliance noted:

15 permit deviations from operating parameters (2015 - 2016)

7 permit deviations from monitoring requirements (2015 - 2016)

12 exceedances of permitted emissions limits (2015 - 2016)

7 permit deviations from fugitive emissions requirements (2015 - 2016)

and 4 "potential odor issues" noted for January 24 2015, January 28 2015, April 17 2015, and January 31 2016. 

The citation indicated the four "potential odor issues" as a violation of Louisiana Administrative Code LAC:33.III.2901. Odorous Substances. The purpose of Louisiana Odor Regulations is to establish an ambient air standard for odors and to prohibit or restrict odorous substances at or beyond the sources' property lines.(page 309 / 357  LAC:33.III )

7. PBF Energy was also ordered to provide more detailed information on various violations towards the H2S concentrations, reported causes, duration of violations, and quantities.

PBF Energy to enter into settlement with State

 State of Louisiana
Department of Environmental Quality
Proposed Settlement 1376 / SA-AE-22-0024

PBF Energy's Chalmette refinery to enter into proposed $100,000 settlement agreement with the Louisiana Department of Environmental Quality for over 50 air permit violations between 2015 and 2019 and numerous additional reporting requirement violations, and other violations PBF Energy requested the LDEQ include in the settlement.

The settlement concerns the State's allegations of environmental violations at PBF Energy's Chalmette refinery that were set forth in the Consolidated Compliance Order and Notice of Potential Penalty, Enforcement Tracking No AE CN 17 00789, Notices of Potential Penalty, Enforcement Tracking Nos. AE PP 18 00720A, and AE PP 19 00542. 

The settlement does not include any environmental projects, local funding, nor offer of any type to compensate the local community. 

The public is invited and encourage to submit written comments. 
REFERENCE AI # 1376   Settlement Tracking number SA AE 22 0024 

Public Notice Dated October 14 2022 in page 3 of link

 https://edms.deq.louisiana.gov/app/doc/view?doc=13481974 

LDEQ will accept comments on the proposed settlement for 45 days from the public notice 

Written comments and requests for public hearing should be sent to: 

LDEQ

Office of the Secretary

Legal Division

P O Box 4302

Baton Rouge, LA 70832- 4302

Attn:  Ashley S Hurst, Attorney

REFERENCE:  Settlement Tracking Number:  SA AE 22 0024 AI 1376

or email deq.publicnotices@la.gov 

Terms and conditions of the settlement at this link

   https://edms.deq.louisiana.gov/app/doc/view?doc=13481974 

For further information contact the LDEQ Legal Division at 225-219-3985

1376 / SA-AE-22-0024 
Enforcement Nos. AE-CN-17-00789, AE-PP-18-00720, AE-PP-18-00720A, AE-PP-19-00542 and additional violations 

particulate matter kills

 Submit a public comment today to EPA Administrator Regan to make stronger, science-based standards for particulate matter. 

Air pollution is so bad in St Bernard Parish, Louisiana that the air quality fails to reach the one-hour health standard for Sulfur Dioxide. The air in St Bernard Parish is non-attainment for SO2. 

Additionally, several areas of St Bernard Parish, Louisiana have high levels of particulate matter in the air and are ranked in the highest 95% - 99% National Percentile for NATA diesel PM, according to EPA's EJ Tool Map. 

There are a serious health concerns regarding the combination of high particulate matter concentrations with the high sulfur dioxide emissions. According to the University of Massachusetts Political Economy Research Institute: Chalmette Elementary, a school with 71% minority enrollment in St Bernard Parish, is in the 3rd percentile for air quality and Martin Luther King Junior Charter School for Science and Technology for Grades K - 12, a school with 100% minority enrollment in the Lower 9th Ward of Orleans Parish, is in the 10th percentile for air quality. It's difficult to learn, develop, and grow in such a degraded environment. Our children deserve better.

There are proven health consequences from having sulfur dioxide and particulate matter commonly co-exist at such high levels in the ambient air. This type of mixed pollution -- high sulfur dioxide and high particulate matter - has long been linked to the development of neurodegenerative disorders and to increased morbidity from cardiopulmonary diseases. New studies show that co-exposure leads to neurodegeneration even at low doses. [1]  

The current standards set by the Environmental Protection Agency (EPA) are outdated and insufficient. Setting tighter limits for particulate matter in line with the levels recommended by a scientific advisory committee earlier this year will protect millions of people, including vulnerable populations like children, the elderly, and people with asthma and other respiratory and heart conditions. Higher exposure to soot has also been associated with higher death rates from COVID-19 in recent years. As is often the case, these health burdens are disproportionately borne by communities of color and low income communities near heavily polluting facilities and high-traffic roadways.

Submit a public comment today to EPA Administrator Regan to make stronger, science-based standards for particulate matter. Submit your comments at the link and Sierra Club will deliver it to the EPA when the comment period opens this fall 2022.

[1]     https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6060696/

SO2 Nonattainment

EPA's finding of failure of air quality in St Bernard Parish to attain the one-hour health standard for sulfur dioxide & response to public comments 

Effective November 4, 2022, the United States Environmental Protections Agency (EPA) has determined that the St. Bernard Parish nonattainment area failed to attain the 2010 1-hour primary sulfur dioxide (SO₂) national ambient air quality standards (NAAQS) by the applicable attainment date of October 4, 2018. This determination triggers the requirements of the Clean Air Act (CAA) section 179(d) for the State of Louisiana to submit a revision to the Louisiana State Implementation Plan (SIP) for the St. Bernard Parish nonattainment area to the EPA by October 5, 2023. The SIP revision must, among other elements, provide for attainment of the 1-hour primary SO₂ NAAQS in the St. Bernard Parish SO₂ nonattainment area as expeditiously as practicable but no later than October 5, 2027... and such additional measures as the EPA Administrator may reasonably prescribe that can be feasibly implemented in the area in light of technological achievability, costs, and any non-air quality and other air quality-related health and environmental impacts.

https://www.federalregister.gov/documents/2022/10/05/2022-21249/finding-of-failure-to-attain-the-primary-2010-one-hour-sulfur-dioxide-standard-for-the-st-bernard

For more information on Sulfur Dioxide in St Bernard Parish and background information on the ambient air quality standards for SO₂  https://www.regulations.gov/comment/EPA-R06-OAR-2017-0558-0024

State Agencies investigated for discrimination

 Louisiana State agencies LDEQ and LDH investigated for discrimination amid allegations State officials have let air pollution remain high and downplayed its threat to human health.

Letter: EPA finds strong evidence state agencies have left Black residents living near Denka and throughout the Chemical Corridor disproportionately exposed to harmful pollutants

by Joshua Rosenberg

October 12 2022

https://thelensnola.org/2022/10/12/epa-finds-strong-evidence-state-agencies-have-left-black-residents-living-near-denka-and-throughout-the-chemical-corridor-disproportionately-exposed-to-harmful-pollutants/?eType=EmailBlastContent&eId=b0b8bfcb-ac55-4106-abfd-9c5b41c77f35

“Based on facts discovered thus far during EPA’s investigation, EPA issues this Letter to present significant evidence suggesting that the Departments’ actions or inactions have resulted and continue to result in disparate adverse impacts on Black residents of St. John the Baptist Parish, St. James Parish, and the Industrial Corridor,” Lilian Dorka, deputy assistant administrator for External Civil Rights at the EPA said in the letter addressed to LDEQ and LDH.

The EPA is conducting an ongoing investigation, in part, under Title VI of the Civil Rights Act of 1964, into complaints the agencies discriminated on the basis of race against Black residents living in the region. The comments in Wednesday’s letter reflect the EPA’s initial investigation into the complaints. 

Save Lake Maurepas

 Tommy Tucker WWL 870 AM Radio

What is the Blue Hydrogen Project? October 13 2022 podcast

 https://www.audacy.com/wwl/podcasts/wwl-first-news-with-tommy-tucker-20319

Cynthia Ebinger joins Tommy to talk about the the Blue Hydrogen Project  and whether its carbon injection plans could threaten Lake Maurepas' ecosystem.

Tune in to WWL 870 AM Radio again on Monday October 17tth for another discussion on this important topic and follow Save Lake Maurepas and Save Our Manchac for more information

https://www.facebook.com/smanchac/

Paraphrasing from the October 13 2022 discussion

Any big industrial activity that involves the Earth's ecosystem needs a watchdog and independent monitoring.

Carbon recapture is a new technology that injects fluid CO2 into the Earth's surface, under Lake Maurepas in this proposed project.

Louisiana as a State already has an extensive network of pipelines and the plan is to use the existing infrastructure.

The carbon will be placed under high pressure to become liquid carbon which is injected into the rock surface under Lake Maurepas where there will be mineral reaction to stabilize the liquid as the carbon becomes part of the rock formations. Ideally, this is to be done in areas with no faults in the Earth's surface, as surface faults would allow the carbon to resurface. When CO2 and methane resurfaces it interacts with the ground water. "You don't want to have happen." 

The State of Illinois has established best practices for this procedure and according to Dr Ebinger it is the expectation that the Louisiana Dept of Natural Resources will require those best practices, including additional monitoring, which Dr Ebinger had stated should be independent monitoring.

Its a rapidly changing technology. Its also considered a transitional technology to offset emissions from a new hydrogen plant proposal to meet zero emissions goals. It does not actually reduce the industry's emissions. It is unclear what the storage capacity of Lake Maurepas is for this type of carbon, as the new hydrogen plant is considered to be operational perpetually

Clear the Air EPA

 Louisiana DEQ and EPA need to step up and do their part to be part of the solution.

Sulfur Dioxide and Particulate Matter concerns in St Bernard Parish

The State SIP for sulfur dioxide in St Bernard Parish should address and restrict all sources of sulfur dioxide emissions to lower ambient air levels so the human inhabitants can at least breathe. That level, at minimum, should be below the one-hour health limit of 75 parts per billion SO2. Louisiana & EPA have delayed a St Bernard Parish SIP for sulfur dioxide. Regulators continue to address an air operating permit at Rain CII Carbon Chalmette calcining. Even Senator Bill Cassidy got involved to delay enforcement. Efforts continue to focus on the challenges at Rain CII in meeting the public health standard. The challenges seem to vary as much as the plant's various operating scenarios and as noted in 2018 public comments: "On April 20 2018 the EPA published in the Federal Register [...] a notice to approve the February 2 2018 Rain AOC as a source specific SIP revision to make it permanent and federally enforceable. Rain considers this proposed rule to be extremely problematic since it simply cannot operate its facility subject to the AOC limits."  

Meanwhile, lung health is at critical risk. A recent study by the University of Massachusetts Political Economy Research ranks neighboring Chalmette Elementary School as low as the Third National Percentile for air quality, and nearby Dr. Martin Luther King, Jr Pre-4 - 12th Grade Charter School for Science and Technology in Orleans Parish Lower 9th Ward in the 10th National Percentile for air quality. 

Our children deserve better. Improvements to State SIPs would greatly improve air quality, public health outcomes, and quality of life, especially for residents who reside on the other side of the fence from the polluting plants.

According to research reporting at ProPublica, Chalmette Louisiana residents in the neighborhoods near the PBF Energy Chalmette refinery and the Rain Carbon CII Chalmette calciner have "an estimated excess lifetime cancer risk from industrial sources of about 1 in 17,000."  "Over the five years ProPublica analyzed, the excess risk here has ranged from as low as 1 in 28,000 to as high as 1 in 12,000. In 2018, the risk was 1 in 12,000."

The Most Detailed Map of Cancer Causing Industrial Air Pollution in the U.S.  by Al Shaw and Lylla Younes, additional reporting by Ava Kofman  November 2 2021 Updated March 15 2022

https://projects.propublica.org/toxmap/