BAAQMD: Costs for daily air monitoring too expensive… poor refineries…
By Benicia Vice Mayor Steve Young, October 23, 2018
The Bay Area Air District (BAAQMD) recently released their proposal on how to deal with the problem of excess ROG (Reactive Organic Gas) emissions from refinery cooling towers. Here are my favorite two sections from their proposed way of dealing (or more accurately, not dealing), with the problem …
Amendments to Rule 11-10 reduce monitoring of cooling towers for hydrocarbon leaks from daily to weekly, with provisions to extend monitoring periods after proving no leaks for an extended time. Costs for daily monitoring were found to be excessive relative to the potential hydrocarbon emission reductions. Requirements for cooling tower best management practices and reporting were eliminated when found to be focused primarily on Process Safety Management and cooling water chemistry rather than leak detection.
The only feasible method to reduce ROG emissions from cooling towers is more frequent monitoring and repair, but this method was concluded to not be feasible due to economic factors as per CEQA Guidelines §15364. Thus, no feasible mitigation measures have been identified that could avoid the significant impact or reduce the impact to less than significant.
Generally, CEQA (the California Environmental Quality Act) does not allow an environmental impact to be ignored based on the fact that reducing those impacts will cost money. And refineries certainly SHOULD be expected to spend money on such things as more frequent monitoring and repairs.
Going to testify at these hearings – where testimony is limited to no more than three minutes, and often shorter – is both necessary and, seemingly, pointless.
From: Roger Straw Sent: Friday, July 06, 2018 9:45 AM Subject: FW: [BAAQMD Coalition] Questionable community outreach for Industrial Safety Ordinance audits
This is amazing – read below, from bottom, up. (Click on the image for larger display.) And then come back and ask a couple of questions:
Does Solano County have to report to the public like this now – even under current regulations? Do they publish a notice like the one Nancy sent from Crockett? Is this something that our newbie “CUPA” needs to be doing on our behalf?
If/when we have an ISO, what assurances do we have the Hazardous Materials staff (Contra Costa OR Solano) would be any more attentive to Benicia citizens’ needs. (Randy Sawyer should be embarrassed by this.)
I think the Working Group could be making a big deal out of this! I think I’ll post about it on the BenIndy.
Begin forwarded message:
On Tue, Jul 3, 2018, 3:28 PM Nancy Rieser via BAAQMD Network wrote:
The Contra Costa Health Department considers a booth behind an elementary school two blocks away from a street fair in Crockett as a “public meeting..” They reckon that the booth where they will be twiddling their fingers while the locals drink and dance a few blocks away will meet its obligation to hold a face-to-face public meeting.
Guess we are lucky. Martinez gets its face-to-face at a Christmas tree farm in August on National Night Out.
I called the Health Department: The gentleman who answered the phone said that apparently nobody cares enough to hear this kind of information and they won’t hold a meeting unless they can get a guaranteed audience of 25 people. Neither will they mail notices to individual homes about their meeting to hustle the crowds. “It is too expensive.”
LATER, VERY INTERESTING!
From: Ralph Dennis
Sent: Wednesday, July 11, 2018 12:26 PM Subject: ISO related
I noticed in the Benicia Herald this morning two public notices for Risk Management Plans prepared by Solano County Department of Resource Management, one for Praxair and the other for Benicia’s Water Treatment Plant. These are part of the 5-year audit review process, I believe, the same reports referenced in the Contra Costa County notice you sent around the other day.
I figured there ought to be one for Valero, so I called the Solano County Department of Resource Management. Turns out the Valero plan was filed in Dec. 2017 and is still under review. The staffer I spoke with who is doing the review is suppose to call me about status. Interesting, I guess: no public meetings planned, copies of plans not available in our library (as in Contra Costa County). He seemed surprised at my question about public meetings, said he could check with management.
At our membership meeting of June 18, PDB voted unanimously (with one abstention) to ask Benicia City Council to support the issuance of an Industrial Safety Ordinance (ISO) for the City of Benicia and approve Mayor Patterson’s request to direct City Staff to review a Draft ISO. Our recommendation was that staff report findings back to the City Council no more than 90 days from June 19, 2018.
Acting Chairperson Craig Snider drew up a resolution following our meeting expressing our concerns, and presented it at City Council the following evening, June 19.
After much discussion lasting until 1 AM, the City Council voted 3-2 to reject Mayor Patterson’s request and to wait and watch what Valero and regulatory agencies do based on recent new regional and state air monitoring regulations, and to engage Valero and regulatory agencies in discussions.
Two Council members qualified their rejection of the proposed ISO. Council members Campbell and Schwartzman stated for the record that if Valero does not install certain Air-District-required “fenceline” air monitors within 6 months, they would vote to impose an industrial safety ordinance. All five Council members also would like to see “community” air monitors.
On motion of Council Member Hughes, seconded by Council Member Schwartzman, Council approved Option #2 in the staff report, directing Staff to monitor Solano County’s implementation of Program Four, directing Staff to meet with Valero and the appropriate regulatory agencies to address the few gaps that exist between Contra Costa County’s ISO and Program #4, including more effective and frequent communications with the City, Valero, and the community, fence line monitors installed within 6 months (while that was going on, the community monitoring could be negotiated), an evacuation plan, and having a report back to the City Council the first meeting in November, on a roll call by the following vote: Ayes: Campbell, Hughes, Schwartzman Noes: Young, Patterson