According to the Federal Registry The Environmental Protection Agency (EPA) is proposing to determine that the St. Bernard Parish sulfur dioxide (SO2) nonattainment area (“St. Bernard area” or “area”) failed to attain the primary 2010 one-hour SO2 national ambient air quality standard (NAAQS) under the Clean Air Act (CAA or the Act) by the applicable attainment date of October 4, 2018.
Submit public comments here on EPA's findings on sulfur dioxide concentrations in St Bernard Parish:
Given the lack of space between the plants and the neighborhoods, EPA should require stricter measures for lower emissions at all sources of sulfur dioxide and particulate matter in St Bernard Parish.
The combination of high PM and SO2 concentrations can be deadly.
According to the University of Massachusetts Political Economy Research Institute tool:
Chalmette Elementary, a school with 71% minority enrollment in St Bernard Parish, is in the 3rd percentile for air quality and Martin Luther King Charter school, a school with 100% minority enrollment in the Lower 9th Ward of Orleans Parish, is in the10th percentile for air quality. That's the environment the LDEQ and U S Senator Cassidy compromised when they convinced EPA to delay enforcement action. That's the environment the LDEQ and Senator Cassidy provided for our school children; that environment is in the 97% and 90% percentiles for WORSE air quality in our nation.
Its past time for EPA to step in and step it up.
The neighborhoods near Rain Carbon CII and PBF Energy's Chalmette Refining LLC are exposed to large amounts of particulate matter and according to the EPA EJSCREEN Map Tool, some neighborhoods are in the 95 to 100% National and State percentile NATA diesel particulate matter.
EPA should protect what good air is left in our communities and conduct both a human health risk assessment and a cumulative impact analysis for the human environments within ten miles of each site of heavy industry in St Bernard Parish; not just for sulfur dioxide, but for all emissions. EPA should consider in St Bernard Parish delay of issuance of all Title V air permits (initial, renewal, and or modification) until the analyses data are reviewed and required improvements incorporated in the air permits.
Given the numerous health and odor complaints from residents in Lower Algiers, Holy Cross, and Lower Ninth Ward neighborhoods in New Orleans, EPA should also consider that the SO2 attainment modeling data will and should designate Orleans Parish non-attainment for the one-hour health standard for SO2. Without such designations, LDEQ will not require lower emissions. The LDEQ air quality monitor network is not robust and has only 29 monitors for the entire State. EPA should consider this lack of appropriate monitoring does not prove an exceedance of the air standard can not occur. EPA should at least consider requiring LDEQ re-install the previous "Entergy" site air monitor in Lower Algiers New Orleans, across the river from Chalmette, and the previous "Arabi site air monitor or a new site monitor in the Holy Cross or Lower Ninth Ward neighborhoods.
EPA should also consider air modeling will and should designate St Bernard Parish non-attainment for particulate matter PM10 and PM2.5 levels.
Innovations in control technology business practices are always evolving and improving and have proven protective of public health and air quality. EPA should require implementation of the best technologies and business practices in both St Bernard and Orleans Parishes. EPA should require LDEQ update its State Ambient Air Standards [AAS] for air toxins, as standards should be reviewed periodically and improved as technology and best business practices improve. When was the last time Louisiana reviewed and improved its air standards?
When EPA conducts these air modeling dispersion studies, all sources should be included. Since the last time St Bernard Parish was designated non-attainment for the one-hour health standard for sulfur dioxide, major sources have re-started previously idled units, which were not likely included in the Louisiana SIP (state implementation plan) to improve air quality. One example is the additional coker unit at PBF Energy's Chalmette Refining LLC which restarted in 2018 for the first time in nine years. PBF Energy's Chalmette Refining LLC recently applied for an initial Title V Part 70 operating air permit for a proposed renewable diesel unit, and citizens who participated in the public comment opportunity for the renewable diesel unit found the application lacked modeling data, and the EAS to be insufficient, incomplete, and not even included in the LDEQ public notice link. [1]
Submit public comments here on EPA's findings on sulfur dioxide concentrations in St Bernard Parish:
[1] https://edms.deq.louisiana.gov/app/doc/view?doc=13032248
https://edms.deq.louisiana.gov/app/doc/view?doc=12993977
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