public participation

Public Participation


http://www.cleanwatershedcampaign.org/public-participation/


The EPA organized a community group to evaluate the success of remediation [by Dow Chemical]. It met a few times, provided critical commentary, and was dropped as Dow completed its EPA required action. Over the years, this would be a familiar model of public participation. If the panel was critical, its life was usually brief. Citizen oversight of one of Michigan’s most powerful Fortune 500 companies would not be popular with regulatory authorities, elected officials or more importantly, the Dow Chemical Company...... Dow itself had (has) a community advisory panel. Its goal was (is) to get honest feedback from the community as to how it was performing as a corporate citizen. Mary Sinclair, Midland citizen, science and communication adviser to the Nuclear Regulatory Commission, didn’t last a year on the panel. She recognized that the company was not forthcoming in information requests or responsive to suggestions – she left.


Is this yet another exercise in futility or is it the finality so many of us
hope has arrived?


Do we participate in good faith? Eight years of Dow’s tactics of denial and delay, eight years of frustration at the state’s impotence. Can the federal government succeed? Can the CAG succeed?


Each individual active in this clean up will have to answer these questions for themselves. I for one am not prepared to let any opportunity to hold Dow and the EPA accountable slip away.


Terry Miller, Chairman Lone Tree Council

no off site impacts, no reportable quantities

no off-site impacts at the plant and no emission permit exceedances

February 2013 releases at Valero cause sulfur dioxide levels to spike (readings of 103, 109, 128, 138 and 180 ppb) http://www.nola.com/environment/index.ssf/2013/02/st_bernard_parish_sulphur_diox.html

October 2013 crude oil spews onto St Bernard Highway (workers evacuated into neighborhood, no offsite impacts) http://www.nola.com/traffic/index.ssf/2013/10/valero_accident_sprays_crude.html

March 22 2014 ROSE unit startup (no reportable quantities, no violations of permits)  http://www.nola.com/environment/index.ssf/2014/03/valero_energy_corps_meraux_ref.html

April 21 2014 Benzene saturation unit explosion (the issue is the emissions are aromatic; it’s only a detonation) http://www.nola.com/environment/index.ssf/2014/04/valero_energy_corps_meraux_ref_1.html

November 2014 MDH unit startup and blown hole in the south flare (Valero noticed a tear in the flare and this will decrease combustion efficiency; MDH unit makes kerosene and diesel) http://www.nola.com/environment/index.ssf/2014/11/valero_energy_corps_meraux_ref_2.html

November 2014 startup of new hydrocracker vessel   …………………………………………………………..

what happens without sidewalks

school students in Louisiana are forced to walk in the street because not all neighborhoods are afforded sidewalks



tragically students in Orleans Parish and more recently in Breaux Bridge have been killed while walking in the street to the bus stop.  Residents of Breaux Bridge hope the incident lease to changes, like sidewalks

http://www.wfla.com/story/27180821/breaux-bridge-address-street-safety

"It's the time to come together as one for the greater good of all of the families that have suffered in this endeavor."" Councilman Menard also told us that although state law doesn't require sidewalks. Since he's been in office he has mandated that every new sub division or development have sidewalks.



In St Bernard Parish, instead of maintaining the newly installed FEMA project sidewalks, parish officials have allowed removal of sidewalks, even claiming an agreement allows sidewalk removal as long as the sidewalk is not currently used as a bus stop. Officials would not answer why students must now walk in the street to get to the bus stop nor have they responded to a public records request for a copy of the agreement to remove sidewalks.

One property owner that has been allowed to remove sidewalks is Valero Energy, a profitable corporation that recently announced third-quarter 2014 earnings of $1.1 billion.  


Certainly they can afford to be a good neighbor and replace sidewalks and improve pedestrian safety!

benzene monitoring proposal is flawed

Public Comment to U S EPA on the proposed "Refinery Rules" 
more information on submitting public comments here







Dear Gina McCarthy,

Global Community Monitor is writing in support of the U.S. Environmental Protection Agency's efforts to strengthen refinery air toxics emission limits and monitoring requirements to protect public health. The EPA must reduce emissions of toxic chemicals from refineries based on the best scientific understanding of the harm this hazardous pollution can cause, especially for children, women of child bearing age and the elderly.

Let me say first we support the bulk of the new rule, except for the flawed so called "fenceline monitoring" section that fails to take into account many important facts as well as the latest technologies which deliver data that actually could inform corrective action by a refinery.

Today I'd like to focus on a huge basic flaw in your staff proposal to use "benzene badges" to absorb two weeks of air at a time to obtain an average of benzene exposures.

As I am sure you are well aware, the largest US refineries are located in clusters in port areas of Texas and Louisiana. In most cases, and there some insignificant exceptions, the refineries are located directly adjacent to one another and share a common fenceline on at least one boundary if not several.

The refinery used for the journal article written to prop up this flawed proposal, was curiously the Koch Brothers West Refinery in Corpus Christi, TX. It is the only refinery in Corpus that does not share a fenceline with its neighbor refineries. Please have your staff justify this choice and rationale to not also study the vast majority of cases where refineries are adjacent.

Obviously, with undeniable variability of wind direction and changes over a two week period, no data of any value would inform corrective action because you can never know which of all the fugitive sources in a refinery contributed to the exceedence of of the risk based threshold. If you add in additional large sources of one or more refinery, there is little that can be said if anything about which refinery could be asked to "correct" the excess. As you know, refineries are skilled at blaming the other guy.

Another reason, there is no value in 2 week averages of benzene in many refinery areas like Corpus, Houston, Lake Charles, Port Arthur, Wilmington and throughout the region is that the refineries are located adjacent to at least one major freeway. This means these refineries could just blame the freeway and object to the plan to correct!

Thanks for listening, Gina!

Best,

Denny

Denny Larson
Executive Director
Global Community Monitor (GCM)
www.gcmonitor.org

Poverty is not an accident. Like slavery and apartheid, it is man-made and can be removed by the actions of human beings.
Nelson Mandela

EPA regs for oil refiners

Comment on EPA proposed refinery rules

• In general, refiners are still in the mode of resisting new government regulatory initiatives and are not acknowledging that reducing pollution is not only good for the environment, but also has an economic return. It is not sufficient to just address current operations in order to establish effective emissions reduction programs. Improvements must begin at the plant design stage in order to eliminate or minimize flaring by integrating flare gas recovery systems, design for smooth start-up and shutdown of process units without flaring, and designing coking units with completely enclosed coke handling systems, to mention a few important areas. Procedural changes and new technology must also extend to plant maintenance. For example, improved monitoring and repair of the seals on floating-roof tanks is essential, as is the use of modern infrared sensors for detecting leaks at valves, pumps and flanges.

Robert Levy                                                       

Chemical engineer, Board of Directors of Air Alliance Houston

Letter to all CEO's of Louisiana Petroleum Refineries

August 29, 2014 Letter from Pete's Articles to CEO's of all oil refineries in Louisiana



RE:  NON ETHANOL GAS IN LOUISIANA DISAPPEARING

Gentlemen:

I am writing to each of the major gasoline producing refinery CEO’s which have crude oil refining facilities in Louisiana to plead with you to help us with more availability of conventional, non ethanol gasoline in Louisiana.

Approximately three years ago, there were five (5) refineries in Louisiana that manufactured and sold non ethanol gasoline to service stations through the State’s 64 Parishes.  These were Murphy Oil Refinery in Chalmette, Chalmette Refining in Chalmette, Marathon Oil Company in Garyville, Placid Oil Company in Port Allen and ConocoPhillips Oil Refinery in Westlake.  These refineries provided an ample volume of non ethanol gas to meet consumer’s needs throughout Louisiana.  HOWEVER, since that time, Valero purchased Murphy Oil in Chalmette and now manufacture only ethanol fuels at that facility, Chalmette Refining discontinued the manufacture and sale of non ethanol gas from their refinery in early June and lastly, Marathon Oil discontinued the manufacture and sale of non ethanol gas from their Garyville refinery in mid 2012.   READ MORE

As you know, south Louisiana is highly susceptible to hurricanes.  In 2012, Hurricane Isaac hit south Louisiana and flooded over 6,000 homes in St. John Parish where I live.  Two weeks before the hurricane’s path was realized, I took my garden tiller out of storage to till a few rows in my small home vegetable garden to prepare for planting my fall crops.  When I pulled the recoil to start the engine, the recoil rope broke. I took the tiller to a small engine repair shop near my home. When I entered the shop yard, I counted over 50 gas powered home generators in his yard awaiting repairs.  The shop owner told me that customers began flooding him with request to repair their generators when the path of the hurricane became known since their generators would NOT start.  The last time they used them in the last power outage with ethanol gasoline and they would now NOT start.  He had to hire extra workers (in addition to his normal staff of four) to take the carburetors apart and clean and re-assemble them as quickly as possible so the customers would have the generators available when power was lost from this hurricane.  And, this was just ONE repair shop. This is just another example of the problems we experience in Louisiana, particularly in south Louisiana when conventional, non ethanol gasoline is not readily available.
 READ MORE

another pleasant valley sunday

again

 

update:   "no unusual incidents"

 

9 3 2014

 

 

9 1 2014

 

 

8 31 2014

 

 

8 30 2014