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

 

 

 

 

 

 

 

sidewalks and school children

In July 2011, FEMA agreed to replace ALL the sidewalks in the neighborhoods; ALL the neighborhoods.  We are tax paying residents who are caught in a bad deal between our local government and a corporation, and all we want is what any other neighborhood in St Bernard would want, including sidewalks. In a recent council meeting, it was discussed that all neighborhoods would have sidewalks and that it didn't matter who removed the sidewalk -- the parish, a contractor, a resident --- that the sidewalk would be replaced in ALL neighborhoods in St Bernard Parish from one end to the other.

 

 

Murphy Oil was to work in coordination to complete the sidewalk replace project (for the sidewalks illegally removed in demolitions in the former buy-up area).   A few months later Valero purchased Murphy and promised to complete the sidewalk replacement project and actually began work. On both Jacob Drive and Despaux Drive many sidewalks were replaced from Ohio Street to St Bernard Highway.

Work continued until the level of the Mississippi River rose to a point where the Army Corp of Engineers stopped construction within so many feet of the levees.  Valero PROMISED to continue the work once the water receeded,  but never did.

Today, August 22, 2014, instead of replacing what was illegally taken, Valero is taking more sidewalks up at the corners of school bus stops.

SOS  School children need sidewalks to get to the bus stops!!

Roundup Recall on Horizon

Tell the EPA and FDA: Immediately suspend Monsanto's Roundup herbicide.

Sign the petition

 http://act.credoaction.com/sign/epa_suspend_roundup 

Petition to EPA Administrator Gina McCarthy and FDA Commissioner Margaret Hamburg:

Evidence is mounting that the massive use of glyphosate, the primary ingredient in Monsanto's herbicide Roundup, is making us sick at alarming rates. Immediately suspend the use of glyphosate.

Not ?

 http://act.credoaction.com/sign/epa_suspend_roundup

In case you weren't sure yet if the massive use of the herbicide glyphosate - also known as Monsanto's Roundup - was cause for concern, here's the sobering takeaway from an MIT senior researcher who just conducted a review of the stuff:
"I’m certain at this point that glyphosate is the most important factor in an alarming number of epidemic diseases.”¹

The introduction of Roundup in 1973 has corresponded with a rise in conditions including celiac disease (gluten intolerance), autism, Alzheimer’s, diabetes, obesity, pancreatic cancer, thyroid cancer, non-Hodgkin’s lymphoma, Parkinson's and others.²

And its use - along with the rates of many of these diseases - has gone stratospheric over the last 15 years, with the approval of Monsanto's GMO "Roundup Ready" crops specifically engineered to tolerate massive exposure to glyphosate. Roundup is now used all over the world on staple crops like wheat and soy, and has become the most widely used herbicide in the US.

Despite these trends, the EPA and FDA still consider glyphosate to be relatively safe and harmless - based largely on unpublished, industry-produced studies. That position is looking increasingly dangerous, and possibly wrong.

Tell the EPA and FDA: Immediately suspend the use of Monsanto's Roundup until it can be proven safe.

Of course - just because two trends match does not mean those two things are related. And in the eyes of the scientific process, just because something looks, swims and quacks like a duck, doesn't make it a duck.

But in the case of glyphosate, there are many reasons to believe it could be related to higher incidence of many diseases.
Glyphosate doesn't just kill weeds. It is an antibiotic (which kills the gut bacteria that make up a significant portion of our immune system and digestive function), a chelator (which strips the body of nutrients needed to fight disease other essential functions), an endocrine disruptor (which affects hormones and leads to birth defects), and impairs the liver's ability to detox (allowing heavy metals to build up in our bodies). And we put nearly 200 million pounds of the stuff on our food each year!
Even worse, the so-called "inactive" ingredients in Roundup may be amplifying the toxic effects of glyphosate by orders of magnitude. One new study found Roundup's overall concoction to be up to 1000 times more toxic than glyphosate alone.³ Yet Roundup's approval is based on tests of only glyphosate, and does not take into account it's possible interaction with other chemicals EPA considers safe.
Another recent study has challenged Monsanto's claim that glyphosate doesn't accumulate in our bodies -- the cornerstone of our government's finding that Roundup is safe -- finding glyphosate levels in breast milk up to 1,600 times higher than the level Europe allows for individual pesticides.⁴
Part of the challenge in finding an absolute link is that long range controlled studies are difficult to conduct - partially because of Monsanto's efforts to control research money and block information.
So we, in effect, have become the subjects of Monsanto's Roundup experiment. There is ample evidence to suggest that this backward system of pesticide approval may be having terrible implications for our health.
The EPA and FDA should immediately suspend the use of Roundup.


1. "Your Food Is Poisoning You," Outside, May 12, 2014
2. "Is Monsanto’s Roundup linked to a deadly kidney disease?," Grist, May 1, 2014
3. "Major Pesticides Are More Toxic to Human Cells Than Their Declared Active Principles," Bio Med Research International, February 26 2014
4. "World’s Number 1 Herbicide Discovered in U.S. Mothers’ Breast Milk," Sustainable Pulse, April 6, 2014

benzene monitors

Residents from Texas, California, Louisiana and Michigan attended the hearing in suburban Houston. It was the second and final public hearing resulting from a lawsuit filed by Earthjustice and the Environmental Integrity Project on behalf of U.S. communities near oil refineries. The suit, filed against the EPA, argued that the federal agency was more than a decade late in reviewing and updating toxic air standards for refineries.

A spokesman for the American Petroleum Institute, and oil and gas lobbying group, testified Tuesday that EPA has determined that fenceline communities are shielded with an "ample margin of safety" from refinery emissions.    
http://www.sfgate.com/news/texas/article/Texas-public-hearing-on-oil-refinery-rules-5668362.php

http://www.huffingtonpost.com/lisa-garcia/communities-near-oil-refi_b_5662559.html?utm_hp_ref=latino-voices&ir=Latino+Voices

 

Port Arthur, comprised primarily of people of color, is located in an area where cancer rates are 15 percent higher among African Americans than they are for the average Texan. And mortality rates from cancer in Jefferson County where Port Arthur is situated are 40 percent higher, according to the Texas Cancer Registry.

 

In Houston, Texas, the largely Latino neighborhood of Manchester is home to the Valero oil refinery and lymphocytic leukemia rates are 56 percent higher for children. This issue is not limited to these communities alone.