St Bernard Parish & Sulfur Dioxide

 

LDEQ to submit to EPA its revised State Plan for Sulfur Dioxide

Comments Due November 26th  

See LDEQ's pubic notice below

On June 2, 2010, EPA strengthened the primary National
Ambient Air Quality Standards (NAAQS) for Sulfur Dioxide (SO2).

EPA revised the primary SO2 NAAQS by establishing a new health based 1- hour standard at a level of 75 parts per billion (ppb). 

As a result, the EPA designated St. Bernard Parish as nonattainment for the new NAAQS, and the air quality in St Bernard has remained nonattainment since. 

Per a recently public noticed DRAFT revised State plan to bring air quality in St Bernard into attainment, the new air dispersion models used by LDEQ resulted in concentrations of SO2 just below the 75 ppb national standard, with the "highest total impact" reported at 74.8 ppb

With such a small margin of safety, attainment status will require strict adherence to federal air permits. The situation may be even more precarious, as this coastal parish is subjected to more frequent and intense weather events that more often result in excess emissions from shutdown, startup, and malfunction events at the major sources.

Additionally, one of the plants, Rain CII Carbon's Chalmette calciner, is often described as the "lion's share" of the sulfur dioxide emissions. Rain's Chalmette calciner has been challenged in recent years to comply with its air permit's requirement to demonstrate compliance through stack testing. Reportedly, the testing probes were prone to melting under the high temperatures at the stack. 

The focus of the revisions to the SIP for SO2 heavily rely on the Rain CII calciner's ability to comply with a new air permit in an Administrative Order of Consent (AOC) between LDEQ and Rain CII Carbon LLC - Chalmette. The AOC is located in Appendix D of the DRAFT SIP; it has not yet posted to Rain's EDMS files, nor has it pubic noticed in the local newspaper.

The modeled impact for the SO2 SIP revision is based on Rain's waste heat boiler operated at a 900 pound per hour rate. We are completely dependent on LDEQ and EPA to get this right and to ensure compliance with air permits in our parish. They've had plenty of time since the 2010 Standard was established, and meanwhile, public health in our community has suffered.

PUBLIC NOTICE  

The Secretary of Louisiana Department of Environmental Quality (LDEQ) published a public notice in the Louisiana Register that the Office of Environmental Assessment, Air Planning
and Assessment Division, will submit to the Environmental
Protection Agency (EPA) a revision to the Louisiana State
Implementation Plan (SIP) for sulfur dioxide. 

(2410Pot3 located at 1592 or page 176 of link https://www.doa.la.gov/media/3xcacocu/2410.pdf )

The revision is available for review via LDEQ’s electronic
document management service (EDMS), AI# 174156
document number 14513604 dated 10/18/2024
https://edms.deq.louisiana.gov/app/doc/view?doc=14513604

or at LDEQ Headquarters, 602 North 5th Street in Baton Rouge

The SIP revision will implement standards required by the Clean Air Act for the nonattainment area. All interested persons may submit written comments concerning the revision no later than 4:30 p.m., Tuesday, November 26, 2024, to Arlys Dalton, Office of Environmental Assessment, P.O. Box 4314, Baton Rouge, LA. 70821-4314, or by E-mail at arlys.dalton@la.gov

EPA EJScreen Mapping Tools Update

 

Use this EPA EJScreen mapping tool to help identify environmental issues and areas that are disproportionately affected.

https://www.youtube.com/watch?v=HZp3AWDJt5A

https://www.epa.gov/ejscreen

Launch the EJScreen tool  https://ejscreen.epa.gov/mapper/

The map includes 13 Environmental Burden indicators on air quality or proximity to pollution sources. 

Under the Socioeconomic indicators tab, the first indicator is the Demographic index which includes two factors: low income and people of color. The second is Supplemental Demographic index, which includes low income, person with disabilities, education less than high school, limited English speaking, and low life expectancy. There are other Socioeconomic indicators such as, under age 5 and over age 64.

Looking at the Socioeconomic indicators together or individually will help identify socioeconomic issues the community might already be experiencing, and how susceptible the community might be to the environmental burdens.

There are supplemental indexes which combine the environmental and socioeconomic indicators; the intention of these indexes is to show where both environmental and socioeconomic conditions are disproportionately high. There are also indexes that show health disparities, climate related burdens, and, critical service gaps.

The map and indexes can be printed or shared in a pdf report.

Such reports could help decision makers better protect public health, safety, wellbeing, and quality of life in the communities they represent.

As an example:

In St Bernard Parish, the residential district around the Will Smith, Jr Elementary School, has a high national percentile of both the population under age 5 and the population over age 64.

Residents in Violet, Louisiana already experience low life expectancy, as indicated by the 90 to 95 national percentile.  

Currently, this residential district is subjected to diesel exhaust (NATA diesel PM) and PM2.5 particulate matter pollution above the national percentile 80 to 90 percent; some areas are exposed to these pollutants at the 90 to 95 national percentile. Each of these pollutants, diesel exhaust and PM2.5 particulate matter, are known lung carcinogens. Diesel exhaust and PM2.5 reduce lung function growth in children, are linked to premature death, and are linked higher risk to other cancers, including breast, liver, and lymphohematopoietic malignancies. 

 

which America are we building for?

Proposed first phases of a federal infrastructure project for a mega container port in Violet, Louisiana constructed around elementary school, playground, ballpark, and existing residential neighborhoods

Full build-out over one thousand acres forested wetlands previously proposed for community park and natural areas with nature walks

These wetlands are worth preserving

Anyone else wondering if the Biden - Harris Administration's Investing in America Agenda was intended to repeat the past mistakes of further marginalizing underserved communities via federal infrastructure projects? 

Were USDOT discretionary grants meant to be the nail in coffin when funding mega container ports in the middle of existing residential districts? next to an elementary school, playground, and ball park?

Should the Investing in America Agenda include threats to local school districts to sell & relocate OR we'll just build around it?

Would any project that literally creates a physical divide and makes a fence line community from surrounding neighborhoods be considered a “shovel-worthy” goal of building an America for All?

Our State of Louisiana and our nation can progress in intermodal terminals without destroying the idyllic, rural-suburban community in Violet. Alternative business models with alternative sites and or the existing state ports working together would provide more efficient, safer means to meet business needs without creating new sacrifice zones.

DEMAND USACE conduct a Full EIS

DEMAND USDOT review its benefit cost analysis (BCA) 

NO PORT New Orleans

SOS Save Our St Bernard

https://www.facebook.com/SoStBernard/

Send Comments to: 

USACE wetlands permit application MVN-2021-00370-EG

Attn Project Manager Angelle V Greer
via email  angelle.v.greer@usace.army.mil 

LDEQ WQC application 240521-01
Attn Project Manager Elizabeth Hill
via email elizabeth.hill@la.gov

U.S. Department of Transportation - OST
Office of the Secretary
1200 New Jersey Ave, SE
Washington, DC 20590

Demand a Full EIS and BCA review on the significant adverse impact on the human habitat, including the disparate socio-economic affects and degrading public health and air quality from port pollution

Demand a public hearing and / or public meeting in Q&A format for decision makers to receive more input on the destruction of over one thousand acres forested wetlands and the irreparable damage to the community and our parish as a whole.

REFERENCE all Comments

MVN-2021-0270-EG
WQC 240521-01
OCM CUP20240330
MPDG Discretionary Grant INFRA

Board of Commissioners' Port of New Orleans

SOS Save our St Bernard

sostbernard.org

https://www.facebook.com/SoStBernard/

These wetlands are worth preserving

Reserve La highest risk of cancer in the State

 

Official Statement from the Concerned Citizens of St. John Parish

on Denka's Emergency Motion to Delay 90-Day Compliance Period

FOR IMMEDIATE RELEASE:

May 31, 2024

RESERVE, LOUISIANA - On April 9, 2024, the Environmental Protection Agency (EPA) finalized a new rule designed to significantly reduce emissions of toxic air pollutants from synthetic organic chemical manufacturing and polymers and resins plants. The rule targets harmful substances such as ethylene oxide (EtO) and chloroprene, which have been linked to serious health risks, including cancer.

Here are the key implications for Denka Performance Elastomer:

1. Stricter Emission Limits: Denka, the largest chloroprene emitter in the U.S., must comply with tougher emission standards aimed at reducing cancer risks for nearby residents.

2. Fenceline Monitoring: The facility will be required to continuously monitor air quality at its perimeter, ensuring adherence to new standards and providing transparency on pollutant levels.

3. Compliance Timeline: Denka has been given 90 days to meet the new fenceline monitoring and ambient air standards, necessitating significant changes to its operations and control technologies.

Denka, located in St. John the Baptist Parish, Louisiana, produces neoprene and employs approximately 250 people. The plant, situated near an elementary school and in an area known as Cancer Alley, has been at the center of environmental and racial justice debates.

Denka's Response:

Denka has expressed concerns over the 90-day compliance deadline, calling it "illegal and politically motivated." The company argues that this timeframe is insufficient compared to the two-year deadline given to other facilities. Denka has filed an emergency motion with the U.S. Court of Appeals to stay the compliance period, warning that failure to extend the deadline may force the facility to shut down.

Community and Environmental Activists' Perspectives:

• “Over the last eight years, Denka has continued to poison the children at 5th Ward Elementary School and our surrounding community. Our loved ones of all ages are sick and dying but that is not a priority for this Billion Dollar Corporation.  This is a moment of reckoning,” said Robert Taylor, Founder & Director of The Concerned Citizens of St. John (CCSJ).  

• “We are pleased with the HON ruling and its 90-day deadline.  Our community has endured 56 years of toxic chloroprene emissions from DuPont and now Denka.  We should not have to endure another day.  The money Denka spent on lawyers appealing this suggested limit should have been spent on lowering emissions to a safe level for our community,” Tish Taylor, Program Manager CCSJ stated.  

• “I was raised on the fence line of Dupont/Denka and lost many of my family and neighbors. I don’t want the future generations of my family to suffer the consequences of chemical exposure as we did. We deserve better,” Tim Keller, Board of Directors, CCSJ.  

• “We live in fear, local governments in Louisiana could soon be allowed to shield business records from public.  These are complicated situations but the human toll is priority number one,” Larry Sorapuru, Board of Directors, CCSJ, emphasized.  

• Sharon Lavigne, founder of RISE St. James, honors the dedication of Denka workers and their families. "There's dignity in a day's work. Every day, hardworking Americans sacrifice themselves to provide for their families. We recognize the hard work of Denka employees and their commitment to their families. Our fight is for their health and well-being as much as it is for our community’s future. This is an opportunity for a just transition rooted in low-income communities of color, who see the need to phase out industries that harm workers, community health, and the planet. At the same time, we MUST provide just pathways for workers to transition to other jobs, with even better pay in alliance with fenceline and frontline communities."

Background:

In 2016, EPA held an emergency community meeting and reported that Reserve, La had the highest risk of cancer in the United States due to emissions of Chloroprene from Denka/Dupont. They suggested Denka should lower emissions to 0.2 micrograms per cubic meter of air. CCSJ has diligently advocated for the safety of St. John Parish. We have traveled to Japan twice to speak directly to Denka’s Board of Directors but were met with open hostility. Profit is their priority.

The EPA's action follows a broader initiative by the Biden administration to address pollution in communities that disproportionately bear environmental burdens. The rule is expected to reduce cancer risks and improve public health protections.

This statement is issued by the Concerned Citizens of St. John Parish in support of the EPA's efforts to protect our community's health and well-being. We stand with environmental activists and residents in advocating for stringent regulations to ensure a safer environment for all.

ABOUT THE CONCERNED CITIZENS OF ST. JOHN PARISH

At CCSJ, our mission is to advocate for the health and safety of all citizens. Starting with our local councilmember, we are committed to holding government officials and industries accountable for the quality of our air, water, and soil.  Additionally, we strive to secure a safe and promising future for the children in our parish while providing leadership to advance our community in various aspects.  Please contact us directly with all inquiries and funding opportunities as we may require a signed letter of support including a wet signature.  

CONTACT INFORMATION

Robert Taylor

504-559-7304

Tish Taylor

504-417-4732

iluvlaplace@gmail.com

Carcinogenic diesel engine exhaust

 

diesel engine exhaust is classified as "Carcinogenic to humans"

PBF Energy's refinery in Chalmette, St Bernard Parish, and adjacent Rain Carbon CCI calciner are within a 3-mile radius of over 58,700 people, 39% low income, and 60% minority. 

Several areas of St Bernard Parish are exposed to a 95% to 99% national percentile diesel exhaust pollution (NATA diesel PM), and areas of St Bernard Parish which are not so exposed will be if the USACE and the State of Louisiana develop over one thousand acres forested wetlands into a massive international terminaling port.                 -- https://www.sostbernard.org/

The International Agency for Research on Cancer (AIRC) is part of the World Health Organization (WHO) One of its major goals is to identify causes of cancer. IARC classifies diesel engine exhaust as "Carcinogenic to humans." According to EPA, in addition to the lung cancer risk, there is significant potential for non-cancer health effects as well, based on the contribution of diesel particulate matter to ambient levels of fine particles. Exposure to fine particles contributes to harmful respiratory and cardiovascular effects, an to premature mortality.

From Our Friends and Fellow Residents in St James Parish and Members of RISE St James 

Chemical of the month --- PM 2.5     by Caitlion O. Hunter, Esq.

"The combination of high levels of PM in the air with other air pollutants in industrial areas is especially dangerous, since PM2.5 can form from or bind to metals and petrochemical pollution released into the atmosphere. Burning diesel as fuel releases a mix of incredibly small particles as well as carcinogenic chemicals; these two then bind together to make a PM that has been found to cause cancer in humans. "

A service program of RISE St. James; Caitlion O. Hunter, Esq.; Tim Schütz, PhD Researcher, Anthropology University of California, Irvine; and The Community Scientist (TCS) Research Team

benzene level updates

 

"Refineries with adjusted benzene levels over 9 micrograms per cubic meter, measured at their fencelines and calculated on an annual rolling average every two weeks, are required to conduct root-cause analyses to determine the source of the benzene emissions and then take action to reduce the pollution."

“Requiring companies to publicly disclose their fenceline monitoring results and to find and fix benzene pollution sources appears to be working,” said Eric Schaeffer, Executive Director of the Environmental Integrity Project. “Although we and others are sometimes critical of EPA, this is an example of a success story of regulations working to helping to protect neighborhoods near refineries from a dangerous pollutant.”

This is a good first step, and hopefully all oil refineries make a commitment to maintain the lower benzene levels.

PBF Energy Chalmette has demonstrated Improved Benzene Levels in recent months, yet for its annual rolling average, PBF Energy Chalmette was 2nd highest in a national ranking by Environmental Integrity Project

https://environmentalintegrity.org/news/cancer-causing-benzene-pollution-from-u-s-refineries-down-significantly/

The benzene level at PBF Energy's Chalmette refinery was over the "action level" from early 2019 to early 2021 , and, has been above the "action level" for the past two years, "with an adjusted annual average of 14.67 micrograms in December." According to the Environmental Integrity Project report, PBF Energy's oil refinery in Chalmette has the second highest average in 2023.

PBF Energy's refinery in Chalmette, St Bernard Parish Louisiana is within a 3-mile radius of over 58,700 people, 39% low income, and 60% minority. St Bernard is also non-attainment for the one-hour health standard for sulfur dioxide, and several areas of St Bernard Parish are exposed to a 95% to 99% national percentile diesel exhaust pollution (NATA diesel PM).

The International Agency for Research on Cancer (AIRC) is part of the World Health Organization (WHO). One of its major goals ts to identify causes of cancer. IARC classifies diesel engine exhaust as "Carcinogenic to humans." According to EPA, in addition to the lung cancer risk, there is a significant potential for non-cancer health effects as well, based on the contribution of diesel particulate matter to ambient levels of fine particles. Exposure to fine particles contributes to harmful respiratory and cardiovascular effects, and to to premature mortality.

air quality alerts

 Both the Chalmette Vista and the Chalmette-Meraux areas of St Bernard Parish were subjected to toxic air emissions with in the last several days.

Valero Energy's Meraux refinery experienced a days-long flaring event that at times emitted dark clouds and high flames. LDEQ's network of air monitors does not include a NAAQS comparable source classified air monitor in that area; given wind conditions and lack of appropriate monitoring, it is uncertain at this time if this incident caused an exceedance of air quality standards. There was no alert made to the community. 

https://www.youtube.com/watch?v=tdgg39tXdxI

A few days later, heavy industrial sources further west in the Chalmette Vista area emitted toxic air emissions as measured at the LDEQ Chalmette Vista monitor as high levels of sulfur dioxide and an exceedance of air quality standards for the same. On April 14 2024, the Chalmette Vista air monitoring station measured sulfur dioxide one hour readings above the NAAQS standard of 75 parts per billion (ppb). The data from the monitoring station indicates the one hour average spiked above 77 ppb and the 5-minute interval levels of sulfur dioxide were as high as 119 ppb.

https://airquality.deq.louisiana.gov/Data/Site/CHALMETTEVISTA/Date/2024-04-14

https://internet.deq.louisiana.gov/portal/DIVISIONS/AIR-MONITORING/AIR-MONITORING-DATA-WITH-INTERVAL-5-OR-10-MINUTES  (select Chalmette Vista site and date range 04 14 2024 to 04 14 2024)

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."

Meanwhile, lung health is at critical risk. A study by the University of Massachusetts Political Economy Research ranks 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. Changes to the State SIPs would result in immediate and significant improvements in air quality, public health outcomes, and quality of life, especially for residents who reside on the other side of the fence from these polluting plants.

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/