Matagorda Island and Galveston Bay Oil Spill

Anna Hrybyk 2

Anna Hrybyk, Program Manager

To our friends living near the Houston Ship Channel, Galveston Bay and Matagorda Island:

We have been tracking the oil spill response to the oil impacting your environment from ship-barge collision near Texas City in the Houston Ship Channel.

ship

To update those of us who are not located in the Galveston area:  As of Monday, March 31, NOAA National Marine Fisheries Service teams report 21 dolphins and 4 turtles stranded. Most of these are in the Galveston area but reports from Matagorda Island are increasing.  All of the dolphins were dead, two turtles were captured alive and are being rehabilitated.  Approximately 150 dead birds have been reported in the Galveston area and 30 in the Matagorda area.

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Xavier Students Participate in Algiers ERT

katiecloseupKatie Moore, Research Analyst

This past Saturday, LABB Emergency Response Team and Xavier University’s freshman seminar class deployed to Algiers to knock on doors and ask people about pollution as a part of our Emergency Response Team outreach.  Even though it was an early Saturday morning with the threat of rain, the Xavier students went in to ERT mode full force and did a phenomenal job!

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The Absurdity of “No Off-site Impact”

katiecloseupKatie Moore, Research Analyst

My name is Katie Moore, and I’m the new Research Analyst here at the Bucket Brigade.  On Thursday of last week I went on my first deployment to Baton Rouge as a member of our Emergency Response Team to talk with community members about ongoing pollution and encourage them to report any pollution they experience to the iWitness Pollution Map.

In my first week here at LABB, I’ve seen pollution primarily from the refineries’ perspectives.  Part of my job as Research Analyst involves reading through the accident reports refineries are required to submit to the Louisiana Department of Environmental Quality and the National Response Center after a pollution release.  There’s a lot of jargon in these reports, and a lot of fancy footwork to try and down play the impact of their accidents.  One of the questions commonly included is whether the accident caused any off-site impact.  Of all the reports I’ve read so far, there hasn’t been a single one that admitted impacting nearby neighborhoods.

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Who Ya Gonna Call? LABB

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Molly Brackin, Monitoring and Evaluation Associate

The first report of flaring at Shell Norco came into the map around noon on Thursday, March 6th.

Four other reports came in to the map about the same large flare over the next seven hours. It is obvious that something was happening at the Shell refinery in Norco, but it’s difficult to find out what exactly is going on- especially since the National Response Center (NRC) website has been down for well over a week. The NRC is who facilities are legally required to report to when an unauthorized release (read: accident) happens. NRC reports show up on the iWitness Pollution Map alongside citizen reports, helping to verify a community’s experience with pollution. When the NRC site is down many people, including us here at LABB, are left wondering what in the world is going on at an offending refinery.

norco

“Refinery Flare extraordinarily high, extremely strong. Very concerned about whether refinery is exceeding air emission standards at this time. Very visible from I10…Could be Shell.” (iWitness link)

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Listening Session Comment on EO 13650: Molly Brackin, Monitoring & Evaluation Specialist

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By Molly Brackin, Monitoring & Evaluation Specialist

Listening Session Public Comment

Executive Order #13650:  Improving Chemical Safety and Security

My name is Molly Brackin, and I am an AmeriCorps VISTA with the Louisiana Bucket Brigade. I have been with the Bucket Brigade since July 2013, as the Monitoring and Evaluation Associate.

This Executive Order acknowledges the importance of better channels of communication between government agencies and first responders, and increasing public access to information about chemical facility risks. In my work with the Bucket Brigade I have had first-hand experiences with the breakdowns in communication during a chemical accident. I have had numerous conversations with community members who were left in the dark following a chemical accident in their neighborhood. The Toxic Release Inventory is not enough. Simply knowing what might be emitted into a neighborhood is very different from what has been released, how much has been released and when.  Citizens and first responders need up-to-date, easily accessible information about chemical accidents that affect their community.  Communities should not have to search for information on the chemicals and pollutants that are affecting them- that information should be given directly to these communities.

The petrochemical facilities in Louisiana have a chronic problem with accidents. In January 2014 alone, there were 62 NRC (National Response Center) reports from facilities.  LABB has an open-source tool to track these accidents, as well as the community impact from these accidents. The iWitness Pollution Map, which can be viewed at iwitnesspollution.org, shows both NRC reports and citizen reports in real-time. When a community member sees, smells, hears or experiences pollution they have the option to call, text, or email their experiences and photos to the iWitness Pollution Map. Community members can also sign up for alerts, so that anytime an NRC report comes in or a neighbor sees pollution, they get an e-mail or a text.

The map is useful in many ways. It helps to geo-locate citizen complaints, therefore validating a community member’s experience. The map also helps first responders know exactly who the problem is affecting, and it provides a visual of the offsite impacts of petrochemical accidents. We use the map as evidence to contest the claim that the accidents happening in these facilities do not have an impact beyond their fenceline. In addition to the 62 facility reports in January 2014, there were 68 citizen reports to the map- many of which complained of odors and flaring. Obviously, more needs to be done to protect the many communities that are risk from their dangerous, polluting neighbors.

 

 

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Marcia Oursler, Petrochemical Accident Researcher: Comment on EO 13650

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By Marcia Oursler, Petrochemical Accident Researcher

Listening Session Public Comment

Executive Order #13650:  Improving Chemical Safety and Security

My name is Marcia Oursler and I have been with Louisiana Bucket Brigade since August 2013.

While many community members are aware of the Toxic Release Inventory (TRI), some facilities within the state of Louisiana do not list up to date information.  When visiting the TRI website on a specific plant, the most recent year listed includes 2012, while we live in the year 2014.  Less than one month ago, community members in Shreveport became aware of chemicals in their air not from nearby industry communications, or a government website, but from a bucket analysis.  If it had not been for this bucket analysis, community members would not have been aware of these chemicals in their air.  Individuals have the right to know what chemicals are being pumped into the air they breathe at work and in their communities.

The bucket sample of which I am referring contained benzene, hydrogen sulfide, 2-butanone (also referred to as methyl ethyl ketone or MEK), chlorobenzene, n-hexane, propene, and toluene.  Benzene is an IARC group 1 carcinogen.  MEK and toluene both represent respiratory toxicants.  Hydrogen sulfide has been linked to exacerbate asthma attacks in addition to other respiratory diseases among residents in close proximity to emissions sources.  While requiring additional more thorough fenceline monitoring is necessary, public disclosure is also needed beyond when a permit limit or reportable quantity is exceeded.  The communities have the right to know what chemicals fill the air of what is in their backyard before accidents occur.

I urge OSHA to enhance information sharing.  I urge OSHA to find additional ways to work with stakeholders to identify best practices.  I also urge OSHA to adopt EPA’s policy for Risk Management Plan (RMP)-listed substances.  The federal government now has an opportunity to implement the precautionary principle.  Chemicals should only be used if proven to be safe to human health.  Various chemicals are used regularly in our state of Louisiana.  Many of these chemicals impact the health of vulnerable populations, especially in the form of respiratory effects.  I suggest that risk management plans be adjusted to include a more thorough list of chemicals for the benefit and welfare of both industry and surrounding communities.  In a world where synergistic relationships are not unheard of for varying substances, it is increasingly important for disclosure to be in the public knowledge.

I sincerely thank you all for your time and for your attention,

Marcia Oursler

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Public Comment on EO 13650: Improving Chemical Safety & Security

 By Anna Hrybyk, Program ManagerAnna Hrybyk 2

Listening Session Public Comment

Executive Order #13650:  Improving Chemical Safety and Security

Thank you for the opportunity to comment.  My name is Anna Hrybyk and I have been the Program Manager at the Louisiana Bucket Brigade since 2008.  The Louisiana Bucket Brigade is an environmental health and justice non-profit whose mission is to support grassroots action to create an informed, healthy society whose culture holds the petrochemical industry and the government accountable for the true costs of pollution.

I have been working with neighborhoods living on the fencelines of the sprawling petrochemical industry across the state and the government agencies that serve them on the issue of improving chemical safety and security with the goal of preventing petrochemical accidents.  Our state of Louisiana is particularly vulnerable, being on the frontlines of both the causes and the effects of climate change.

Louisiana’s 17 refineries, 150 chemical plants, 60,000 oil wells and over 36,000 miles of pipelines produce the most oil and have the second largest refining capacity in the country[1].  Petrochemical accidents average 10 per week in Louisiana, according to the federal National Response Center.  “Since 2007, the U.S. Coast Guard has reported fielding more complaints of oil and chemical spills from the thousands of wells and thousands of miles of pipelines in Louisiana than in any other state, exceeding 4,000 a year.”[2]

There are over 200,000 people and 90 schools and daycares within two miles of a refinery in Louisiana.   Many of these communities are so close the facilities their foundations shake when the flare rumbles, they can hear workers inside the plant talking on the intercom and dangerous gases routinely emitted by the plants get trapped in people’s homes making it more dangerous to be inside than outside at times.

There are four areas that need strengthening in order to improve chemical safety and security and prevent petrochemical accidents.

  1. EPA’s Risk Management Plan Program

First, EPA’s Risk Management Plan program needs to improve its method of targeting of high risk facilities for inspections. I believe EPA’s targeting can be better if EPA correlates other information sent to OSHA, the National Response Center, the state police and the state department’s of environmental quality.  EPA currently only relies of what industry self-reports in their Risk Management Plans every five years.  As I will show, this Plan often contradicts what company’s report to the state and other federal agencies.

In October 2010, the Louisiana Bucket Brigade reviewed the ExxonMobil Baton Rouge Refinery Risk Management Plan (RMP) while visiting EPA Region VI in Dallas.  Our review shows that the RMP as written does not comply with CAA(r) 40 CFR Part 68 Accidental Release Prevention.

Though the facility’s RMP states that they have no accident history to report for any of the processes covered by the RMP, the refinery’s own upset reports show that EMBRR has reported the following to the LDEQ and/or State Police from 2005-2010.

No. Unit/Process Number of incident reports to LDEQ involving unit Amount of pollution reported (pounds)
1 Alkylation

11

68,210

2 HHLA

2

23,737

3 HCLA

2

235,614

4 PHLA

3

13,085

5 RHLA

3

272,455

6 T-210

2

BRQ

7 ICN

4

12,720

8 LEU

1

141,780

9 Propane Storage

3

4,239

10 Gas Collection

1

5,347

11 PCLA

5

149,099

TOTAL

37

926,286

None of these were self-reported to EPA’s Risk Management Plan as required by law.  Some of these incidents were catastrophic.  On May 7, 2009, an incident on the PCLA unit (LDEQ#114733) led to Carbon Monoxide exposure among nine employees.  According to OSHA, this occurred because the venture nozzles were corroded, including one steel shell that had rusted to the point where the material was paper-thin.  Fires were frequent at EM BRRF in 2010.  On April 14, 2010 a flash fire occurred at the refinery sending two contract workers and one EM employee to the burn unit at Baton Rouge General Hospital.  No information was given regarding the root cause of the fire.  This was the second of five fires at the facility in 2010.

Second, increase the number of RMP inspectors working in Region VI because of the high volume of hazardous facilities located in populated areas.  Currently there is only one inspector and one trainee based out of Houston.  That is nowhere near enough to prevent accidents.

Third, improve the enforcement of violations found in the RMP inspections to make sure they are concrete, meaningful actions toward the prevention of accidents.    After a 2011 RMP Inspection of the Calumet Refinery in Shreveport which found nine violations including failure to accurately report, failure to inspect equipment and monitor for hydrogen sulfide, the community had to wait two and a half years until EPA and Calumet agreed on the penalty.  In November 2013, EPA and Calumet agreed on a civil penalty of a little more than $300,000 and required the installation of 32 fenceline sensors that test for sulfur dioxide, hydrogen sulfide and flammable vapors.  The data from those sensors was not required to be made publicly available therefore the enforcement action does little to improve chemical safety and security.

Also, EPA conducted an RMP inspection of ExxonMobil Baton Rouge Refinery (mentioned above) in June 2012 and there still has been no penalty issued by the EPA for the violations found in that inspection.  Violations include failure to accurately report and the failure to inspect, test and maintain over 1,000 lines in the facility despite pervasive corrosion.  If the RMP program is going to prevent accidents, then enforcement of the violations found in the inspections needs to be timely and strong enough to deter non-compliant behavior in the future.

2.  Local Emergency Planning Commissions (LEPCs)

The Local Emergency Planning Commissions are great in theory, but in practice they are not legally enforceable (meaning you cannot force a defunct LEPC to meet or include community representatives for example) and they have no enforcement power to preventing accidents.  In October 2011, LABB conducted a review of the East Baton Rouge Parish Local Emergency Planning Commission’s (LEPC) Emergency Operations Plan (EOP) and found it in violation of EPCRA Sections 301-303.  The East Baton Rouge Parish EOP fails to protect the neighborhood living within 2 miles of the EM BRRF in the event of an accidental release.

  • Although the EOP is supposed to be reviewed annually, there appears to have been no review since 2009.
  • The EOP does not provide information about chemicals in the community or any information regarding key facilities and hazardous transportation routes within their community.
  • The EOP does not show a designated community coordinator to help implement the plan.  The LEPC also makes no mention of a community member serving on their committee.
  • The EOP does not mention any specific populations/neighborhoods that are susceptible to threats.
  • The EOP shows the locations of sirens within the parish, for notification in the event of an emergency, but it does not go into detail about what citizens are supposed to do once they hear a notification over the siren, which petrochemical facilities use the sirens and who is designated to maintain the sirens.
  • The EOP does not state specific dates when training exercises will be executed, or how often they should be executed. It also does not incorporate specific facilities and/or community members in the training plans.
  • The plan makes no mention of environmental monitoring and/or sampling during and post-incident.

If the LEPCs are to be taken seriously by industry and emergency responders from various agencies, then the LEPC needs to be better funded and given enforcement discretion.  This in turn will ensure that LEPCs are more involved during the response to chemical emergencies as well as in the prevention of them.

3.  Improving information for first responders and impacted communities

One best practice in improving chemical information for first responders and impacted communities living nearby to industrial hazards is requiring fenceline monitoring on the periphery of all plants located in populated areas.   Currently the Clean Air Act does not require this and a change in the rule is necessary in order to protect communities.  Fenceline monitoring should monitor for multiple pollutants that are known to adversely affect health (i.e. benzene, sulfur dioxide, hydrogen sulfide and a range of volatile organic compounds) the data it collects should be made available to the public in real time.  Often simply public disclosure of air monitoring information can improve compliance of the facility.  This effort requires no funds from EPA  – only a well-written rule requirement of industry.  This effort will also go long way in operationalizing the precautionary principle.

The best fenceline monitoring system that we have seen put in place and  provides the best quality data on emissions is the recent Chevron Refinery in Richmond, California following the huge fire in 2012 that sent thousands to the hospital.

  1. Community air monitoring stations (Continuous Auto Gas Chromatograph, MetONE PM Sampler, TO-15 Discrete Grab Samples) located in all residential areas within 1 mile of a petrochemical complex measuring for PM 2.5, PAHs, H2S, ammonia, ozone, benzene, toluene, ethylene, xylene 1,3 Butadiene, dichloromethane, carbon tetrachloride, tetrachloroethylene, vinyl chloride, and ethylbenzene.
  1. Continuous Open Path UV and Continuous Boreal Tunable Diode Lasers along all perimeters of a petrochemical complex next to residential areas testing for benzene, toluene, p-Xylene, sulfur dioxide, carbon disulfide and hydrogen sulfide.

4.   Improving Chemical Safety Board

Lastly, the U.S. Chemical Safety Board has very skilled inspectors who astutely analyze chemical accidents and make recommendations on how to prevent them in the future.  The CSB reports are accurate and well written but the CSB as it exists today has no enforcement discretion to hold the industry and government accountable for following its expert recommendations.  This Executive Order would be well served to give the CSB enforcement discretion to see that its recommendations are carried out much like the RMP program is.

Thank you for your time and attention to my comments.

Sincerely,

Anna Hrybyk
Program Manager
Louisiana Bucket Brigade

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