The Bay Area Air Quality Monitoring District (Air District) is planning to finalize a rule that would reduce pollution from the Chevron and PBF (formerly Shell) oil refineries in Richmond and Martinez—two of the largest refineries in the world. Due to pressure from the fossil fuel industry, the Air District is seriously considering a weak version of the rule.
This is where you come in. The Stationary Source Committee of the Air District will be meeting to consider this rule on December 17th, which is why we need your (or your organization’s) signature by December 15th, 2020.**
- Petition link for individuals: bit.ly/STRONGEST_RULE
- Petition link for organizations: bit.ly/STRONGEST_RULE_ORG
If the Air District were to adopt the strongest rule possible, this would be the boldest action they will have taken in years to cut their pollution to stop harming communities of color. We all need to push the Air District to adopt the strongest rule possible.
To learn more about Rule 6-5, the Cat Cracker Rule, and why it needs to be as strong as possible, please read this short CBE fact sheet, or a slightly more detailed brief here. A longer explanation of the issues is provided below.
The Air District’s regulation page with ongoing updates for Rule 6-5 is here.
** If you or your organization’s members are able to testify at the Thursday, December 17th BAAQMD Stationary Source Committee meeting, please email Andres Soto at firstname.lastname@example.org.
Thursday, December 17 11:30 AM – 5:00 PM
Zoom access, agenda and presentations will be available on BAAQMD website prior to the meeting.
The following material provides a deep dive into the technical issues. In summary, we are urging BAAQMD to include benefits in its cost-benefit analysis, to compute the costs more fairly, and to require Chevron and PBF to adopt wet scrubbers in order to more fully reduce their deadly particulate matter (PM) emissions. Wet scrubbers are the best available technology for the job and our refineries should be using them. We hope this will assist you with talking points:
General Health Impacts of Particulate Matter – PM 2.5
• PM2.5 is the main cause of health impacts from air pollution. Here in the Bay Area, an estimated 2-3,000 people die every year because of PM2.5 exposure.
• BAAQMD ‘s Technical Advisory Council (the “TAC”) has determined that there is no safe level of P.M 2.5 exposure without health impacts, and that the current Federal standard for regional PM2.5 exposure limits is inadequate: its standard of 12 micrograms/m3 is not health protective and should be lowered to at least 8.
• The TAC has also determined that local and hyper-local emission sources primarily impact low-income and people of color communities, adding to their health risks.
• The primary industrial stationary sources of PM 2.5 emissions under BAAQMD regulatory authority are the five refineries. Staff reported at the 10/1/20 Stationary Source Committee meeting that total PM emissions from two refineries with Fluidized Catalytic Cracking Units (FCCUs, or cat crackers), which break down heavy crude oil stocks into usable fuels, represent 30% of PM emissions from BAAQMD-regulated sources, with the cat crackers responsible for half of the refinery PM emissions.
• Refinery PM2.5 emissions have additional health risks due to their heavy metal content. Heavy metals are associated with processing heavy petroleum products, and are not present in other PM emissions from wood burning and fire smoke.
• 3/4 of a million Bay Area residents are impacted by refinery PM2.5 emissions (subject to incremental exposure of 0.1 ug/m3 PM2.5 from cat crackers).
• Disproportionate local health impacts of PM2.5 emissions are quantified by studies such as the Harvard analysis of COVID-19 mortality rates, which found an 8% increase in COVID- 19 mortality rates for every 1 ug/m3 increase in average PM2.5 exposure levels. Higher PM exposure levels for low-income and people of color communities is a major driver of their higher COVID mortality rates. Latinx and Black communities are exposed to cat cracker-emitted PM 2.5 at rates 1.4 and 2.6 times higher, respectively, than the general Bay Area population.
• Because BAAQMD lacks the authority to adjust the Federal 12 ug/m3 standard, it must take steps to reduce PM exposures by exercising its authority to regulate regional, local and hyper-local sources of emissions.
PM 2.5 Cat Cracker (FCCU) Strategy
• BAAQMD is required to adopt Best Available Retrofit Control Technology (“BARCT”) under state AB617 requirements to protect the health of communities disproportionately impacted by PM2.5 emissions.
• There are two proposals on the table for meeting overall PM emission reductions:
⁃ The higher emission level can be achieved using Electrostatic Precipitation Systems (ESP), which will achieve approximately a 40% reduction in overall PM 10/2.5 emissions, but
⁃ the lower emission level will probably require going to wet gas scrubbing (WGS), or wet scrubbing for short, which has been shown to achieve up to a 95% reduction in total PM emissions.
• Based on the required socioeconomic analysis that must be included in the rulemaking process, BAAQMD staff to date has sided with refinery opposition to the tighter standards. It has recommended against adopting the stricter, BARCT-level lower-emission standards. This position is not defensible because:
• The rulemaking process requires BAAQMD to consider what it would cost the refineries to implement any changes, but it does not require BAAQMD to provide measures of the costs of health impacts on impacted communities.
• For this reason, current health impact analyses by BAAQMD staff only include comparisons of estimated health costs of mortality rates associated with each emission level. They do not account for broader health impacts such as respiratory impacts (communities adjacent to refineries have the highest child asthma rates in the state), other heart and lung disease, and other long-term health impacts.
⁃ Staff insists they are using Federal EPA’s Benefits Mapping and Analysis Program (BenMAP). The BenMAP claims program can estimate health savings from reductions in heart and respiratory (asthma) problems, including lost work, hospital admissions, emergency room visits, etc. However, BAAQMD staff has never incorporated these factors into its own PM health risks analysis.
• Using self-imposed limitations on health impacts analysis, BAAQMD staff have estimated that the higher emission level associated with ESP will result in 1.2 few deaths per year, compared to 1.7 for the lower emission levels associated with wet scrubbers. The incremental savings at $10 million/year/death result in a lower savings of $125 million over 25 years compared to estimated operational costs of wet scrubbing technology of $300 -700 million. (The higher limit is based on unsubstantiated claims from industry as to costs of wet scrubbing, which they claim are prohibitive.)
• If total savings of the lower emission levels are compared to the projected lifetime capital costs, the health savings of preventing 1.7 additional deaths per year outweigh the costs to the refineries. And by the time these costs are impacting refineries, they will be in a much stronger economic position than they are currently during the pandemic.
• Staff wet scrubber-related cost estimates are based upon a six-year lifetime, rather than a more realistic lifetime of 25 years.
• BAAQMD staff continue to ignore the cost risks associated with the demonstrated risks of explosion hazards associated with ESP. (An ESP-related explosion at Exxon’s Torrance refinery caused billions of dollars in losses.)
• If the refineries passed on the incremental cost of wet scrubbers over electrostatic precipitators, it would result in a 1 cent/gallon increase in the price of gasoline. Such a negligible amount would not be noticeable within the typical market variations of gasoline pricing.
• Staff estimates that the wet scrubber cost crosses the threshold at which refineries would begin to lay off workers to recover costs. However, initial analysis by CARB indicates that this threshold value may be too conservative (i.e., incorrect). Staff analysis also ignores the high job creation accompanying wet scrubber installation: the Valero wet scrubber project created 200 construction jobs. Staff also ignores the fact that refineries require full staffing even if they reduce production throughput—they cannot operate at all with reduced staffing.
• Wet scrubbing has been broadly implemented across the U.S. and is a widely used technology. The EPA has determined that a majority of U.S. cat crackers already use wet scrubbers.