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 hours3.7 Tons (7400 pounds) SO2 within one hour and a half0.41 Tons (820 pounds) SO2 in less than 2 hours3997 pounds (nearly 2 Tons) SO2 in less than 30 minutes1665 pounds (0.83+ Tons) SO2 within 17 minutes9072 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.
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