August 7th, 2015 – my first email submitting comments, on issues other than climate change. Part two focuses on climate change.

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In this document, I am listing all comments on the scope of the WesPac 2015 RDEIR other than those related to climate change.

Pipeline and tank integrity issues

When I refer to “pipelines”, I mean both the pipelines fully internal to the site, as well as the external pipelines that connect to the regional refineries and other distribution networks.

Please include detailed information about the age of all tanks and pipelines. Which of these tanks will be refurbished?

What are the limits of vapor pressure that the tanks and pipelines can handle? How does this compare to the known very high vapor pressure of Bakken shale oil?

What other effects does crude type have on pipeline or tank integrity? For example, both tar sands dilbit and Bakken shale are likely to be more corrosive than fuel oil or other crudes, and the more viscous tar sands dilbit is likely to be pumped at higher pressure than other crudes. Tar sands dilbit is also often heated to get it to flow; how does this affect pipeline integrity? It could increase corrosion and it could also increase wear-and-tear from thermal expansion and contraction.

The Mayflower spill in Arkansas was a result of the rupture of Pegasus, a 65-year-old pipeline that was intended for refined products. Exxon 1) reversed the flow and 2) sent more corrosive tar sands dilbit down the pipe 3) at high pressure. All three actions stressed the already quite old pipeline; together, they weakened it enough to rupture it.

Continue reading “Comments on the scope of the WesPac EIR, part 1” →

The folks over at 350 Silicon Valley have made a web page that explains really easily how to send a letter to the EPA regarding the Clean Power Plan (the plan to limit climate-related pollution from coal plants). Their aim is to send 1000 letters by the deadline of December 1st – and they already have almost 800!

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To Whom It May Concern:

I support the Clean Power Plan and recommend that it be made as strong as possible.

Everything the climate science tells us is that things are worse than we thought: our impacts are greater, our limits are lower, than we thought just a few years ago.

There are several possible “tipping points” that we may cross soon regarding global warming that could make our planet toxic to most life as we know it.

It is imperative that we address climate change with drastic and immediate measures, harshly limiting the use of all fossil fuels, from coal to natural gas.

Please do everything in your power to curtail the use of fossil fuels and promote renewable, clean energy.

Sincerely,
Martin MacKerel

Apparently Kern County wants to increase crude-by-rail and re-open a refinery. That’s a horrible idea, since we need to start closing refineries and move to all clean energy, immediately. Here is my letter of comment, sent through an action page hosted by the Center for Biological Diversity.

Comment

Subject: Reject the Alon Bakerfield Project
You would do well to read California Attorney General Kamala Harris’s January 15th, 2014 letter to the City of Pittsburg, CA regarding a proposed crude-by-rail terminal there. Many of her concerns apply to this project, including:

• the issue of cumulative emissions on an already highly-impacted community,
• the increased and novel risks of transporting extreme crudes such as diluted tar sands bitumen and Bakken shale oil, and
• the effects that new fossil fuel infrastructure may have on California’s ability to meet its own (legislated) greenhouse gas emissions goals.

The full letter is available at http://pittsburgdc.org/?p=655

To protect our climate and meet California’s greenhouse gas emission goals, we must not build any more fossil fuel infrastructure. Period.

Martin MacKerel

Update

The letter can be found at https://www.scribd.com/document/200688980/Letter-from-Kamala-Harris-CA-Attorney-General-to-Pittsburg-regarding-the-WesPac-EIR

The “Refining Emission Tracking Regulation” is a proposed rule for the Bay Area Air Quality Management District. Some groups are trying hard to make sure that it requires reporting of the types of crude oil the refineries take in. I agree with this goal, as you can see from the letter below.

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To: Stationary Source Committee
Bay Area Air Quality Management District
939 Ellis Street
San Francisco, CA 94109

Re: Comments on Petroleum Refining Emission Tracking Regulation, Greenhouse Gas Emissions, and the Regional Climate Action Strategy

As you are no doubt aware, in November the Board passed a Climate Action Resolution (Resolution No. 2013) committing to a goal of reducing greenhouse gas (GHG) emissions to 80% below 1990 levels by 2050.

Very few people have grappled with the enormity of this task. As luck would have it, just last night I was beginning to prepare for a presentation on the topic and I started working on a graph to illustrate the problem. I am not pleased with the aesthetics of the graph, but I am including it on the following page because it’s the best thing I have on hand at such short notice (I found out about this meeting and the submission deadline just a couple hours ago).

A picture is worth a thousand words, but a poor picture requires a few dozen words for clarification.

Although the graph is lightened only from 2014 onward, it is based on BAAQMD’s 2010 report, so the 2011 and 2014 numbers are projections. Nevertheless, you can see that BAAQMD was assuming a linear increase in all sources of greenhouse gases.

The thick black line goes from the 2014 point to Executive Order S-3-05’s 2020 goal (matching 1990 levels) and then to the 2050 goal. The most important point to take away from this graph is that today’s refinery emissions are by themselves almost as high as the 2050 goal for all sources.

It is clear that along with other sectors, the refineries must decrease their GHG emissions. Unlike other sectors, however, a large proportion of refineries’ emissions are inherent to the core function of the industry.

The Bay Area refinery industry will have to contract, not only to meet the lower regional emissions caps, but also because of reduced demand of fossil fuels due to other sectors reducing their GHG emissions.

It is important that BAAQMD keep a very close eye on refineries’ GHG emissions, and one of the most important determinants of their emissions is the type of crude oil (aka feedstock) that the refineries take in. BAAQMD must recognize that the Refinery Emission Tracking Regulation is a key tool to meet its own Climate Action Resolution and will be part of the Regional Climate Action Strategy currently being developed.

For this reason the Refinery Emission Tracking Regulation should be as thorough as possible, it should include reporting and monitoring of refinery feedstock as well as strong punishments for misreporting, and it should be enacted reasonably quickly.

Yours,
Martin MacKerel

Update (2018-09-06)

Four and a half years later, BAAQMD has failed to implement any such regulation.

 

For background, see the Contra Costa article on Oil storage and transfer facility proposed for Pittsburg waterfront. We need to make sure that NO MORE FOSSIL FUEL INFRASTRUCTURE is built. (Pittsburg is a town in the San Francisco Bay Area.)

 

To Whom It May Concern:

I am writing about the proposed WesPac Pittsburg crude oil storage facility.

Such a facility would risk the health of nearby residents by unusual events such as spills. Its day-to-day operations would doubtless also aggravate the existing asthma epidemic in Pittsburg.

Even if the facility operated flawlessly, however, it would contribute to the increased global use of fossil fuels, which generates greenhouse gases that through climate change endanger our physical infrastructure, our health, our environment, and potentially the very viability of human civilization.

It is imperative that we change our energy system. To start with, we must insist on NO MORE FOSSIL FUEL INFRASTRUCTURE.

There is simply no excuse to do otherwise; any statement of environmental impact that claims low impact for additional fossil fuel infrastructure and allows its construction is extremely irresponsible.

Yours,
Martin MacKerel