Louisiana Bucket Brigade
http://www.labucketbrigade.org/
http://www.scribd.com/doc/183372910/Mission-Zero-Accidents
Mission: Zero Accidents. Why Cooperation to Reduce Accidents at Louisiana Refineries is Needed Now. Report has the objective to end refinery accidents.
- At issue with the accident reports from 2012 (the most recent data available) is underreporting by refineries as well as sloppy reporting. Refineries provided no information about 11% of their accidents. In Shreveport, 12% of Calumet Refining’s reports were not filed until community members called the state agency and forced the reporting.
- “It is essential that refinery incidents get reported because that is one of the first steps in protecting the employees and the community,” said USW International Vice President Gary Beevers. Accident emissions have increased over the last several years.
- "There is nothing more fundamental for workers' and communities' right-to-know than a robust system of reporting chemical releases, and making the data easily available," noted Celeste Monforton, DrPH, MPH, policy co-chair of the Occupational Health & Safety Section, American Public Health Association. "LABB's report confirms what workers and residents have known for years----petrochemical companies too often skirt the laws for reporting serious incidents."
Other issues with 2012 Reporting and LDEQ Inspections
Example One - Sleepless night for the neighbors on April 13, 2012.
This was a night of loud, flaring-associated noises emanating from the refinery, causing residents throughout the neighborhood to lose sleep. Residents report to DEQ at one-thirty in the morning April 14th 2012 that the noise from the refinery is audible in the house and kept people awake throughout the early morning hours of April 14, 2012.
DEQ reports in EDMS 8395781 surveillance on April 14 2012 finds no odor, no flaring or loud noises.
DEQ reports search of its own database revealed no reports of releases or upset conditions.
DEQ reports review of information provided during community meeting found no deviations for the time of the complaint.
DEQ noted no further action at this time.
DEQ EDMS 8395781 posted in late May 2012.
FACT: There was an emergency shutdown on April 10 2012 due to power failure. The disturbing noise audible in homes was during the ‘startup’ flaring on April 13th – April 14th.
FACT: The refinery submitted an unauthorized discharge for Incident T 138647, in EDMS document 8387256 reporting the episode occurred from approximately 9:30 on April 10 2012 to 8:00 on April 14 2012 for a duration of 94.5 hours and over 4,000 pounds of Sulfur Dioxide.
FACT: Flare emissions were "off the chart" as shown in community meeting slide numbered 9. (Shown in slide on page 9)
Coincidentally, the ambient air monitor was not working during the startup of April 13th - April 14th 2012.
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Example Two: noxious odors effect neighbors across the river
noxious odors from the last 4 - 5 days in the early morning hours
DEQ does not survey area on other side of river. Instead, DEQ survey of Jacob Drive on December 14 2011 detects strong odor on Jacob Drive, similar to a burnt chemical odor. In April 2012, after DEQ’s five attempts to received information from the facility, the refinery responded with information on two process unit upsets on December 10th and December 13th 2011 and that these events did not exceed permit limits.
Without reviewing plant logs or refinery CEMS data, DEQ concludes these events did not exceed permit limits or reportable quantities. No further action at this time.
FACT: The refinery submitted an unauthorized discharge for Incident T 135917, in EDMS document 8266494 and followup in EDMS document 8286717, reporting a release of 3,500 pounds of sulfur dioxide and 35 pounds of hydrogen sulfide, resulting from operator error.
FACT: Sulfur dioxide reading at Valero's Ventura Drive ambient air monitor on measured an average of 33 ppb SO2 with a maximum reading of 176 ppb SO2; hydrogen sulfide levels were 5 ppb H2S. (Shown on page 4 of slides)
FACT: The refinery reported several air permit exceedances from both the December 10th FCC unit shutdown and the December 13th 2011 NHT debutanizer overhead valve opened to flare resulting in a hydrocarbon flaring event. . VOC and other pollutants released from the South Flare in excess of limits.
FACT: DEQ has access to CEMS data upon request. There is a recent request from residents for a copy of this particular CEMS data from the community meeting. Notes from the community and CAP meetings indicate several air permit exceedances, including: sulfur dioxide at the sulfur recovery unit at 500 ppm (permit limit 150 ppm), hydrogen sulfide at fuel drum 300 ppm (permit limit 162 ppm), and over 1,000 pounds of sulfur at the flares. CAP meeting information is not made available to the public. .
FACT: DEQ has access to CEMS data upon request. There is a recent request from residents for a copy of this particular CEMS data from the community meeting. Notes from the community and CAP meetings indicate several air permit exceedances, including: sulfur dioxide at the sulfur recovery unit at 500 ppm (permit limit 150 ppm), hydrogen sulfide at fuel drum 300 ppm (permit limit 162 ppm), and over 1,000 pounds of sulfur at the flares. CAP meeting information is not made available to the public. .
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Example 3: resident reports fuel odor in air on January 29 2012 and on January 30 2012 flaring with associated noise, odors (gaseous and fuel like at times with mix of sulfur)
FACT: DEQ surveillance Feb 2 2012 did not note any odors.
DEQ inquiry by email to refinery; reply that the facility didnot receive complaints for noise or odor, so unable to verify or dispute these claims. Further the email states ..."reviewed all of our data from our CEMS, and there were no upsets or permit deviations." Again, without further review, DEQ concludes no further action at this time.
FACT: CAP meeting notes permit exceedances reported from ALKY unit shut down and propane tanks venting to flare for 8 hours, including permit exceedance for VOC’s and other pollutants at the South Flare. CAP meeting notes are not available to the public.
FACT: Valero’s Ventura Drive ambient air monitor measured hydrogen sulfide at 24 ppb H2S.
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Example 4: 500 pounds sulfur dioxide released yet not a reportable quantity (RQ).
Valero refinery subtracts baseline sulfur emissions from upset releases to determine “RQ” amount of sulfur dioxide and permit limits.
FACT: May 2 2012 Valero plant effected by power distribution lightning strike. This incident resulted in excess emissions of sulfur dioxide above the Reportable Quantity at the flares and SRU’s. http://edms.deq.louisiana.gov/app/doc/view.aspx?doc=8485733&ob=yes&child=yes
FACT: May 8, 10, and 11, 2012 odors emanating from plant enters homes and cause health effects. DEQ surveillance of area the following week does not result in notation of odors, and DEQ states facility did not report any exceedances or permit violations. http://edms.deq.louisiana.gov/app/doc/view.aspx?doc=8705259&ob=yes&child=yes http://edms.deq.louisiana.gov/app/doc/view.aspx?doc=8705251&ob=yes&child=yes
FACT: Valero flares emitted over 600 pounds sulfur dioxide. (page 13 0f slides)
FACT: Valero doesnot consider this a RQ because at the time of the upset the baseline emissions for sulfur dioxide were 300 pounds. Valero subtracted 300 pounds from the pollution releases. Valero not only concluded the release was not a reportable quantity, but that it was also below some sort of variable permit limit. (Shown on page 13 of slides)
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