The right to ‘know what goes up your nose’
Shell still hasn’t committed to installing fenceline monitoring at the Beaver Country cracker site.
How it worked in other communities and why environmentalists say it’s essential.
July 11, 2017
At some point in the early 2020s, Shell’s $6 billion cracker on 340 acres along the Ohio River in Beaver County will begin to produce polyethylene, the main feedstock for plastic.
As a petrochemical plant, it will emit a whole bunch of chemicals into the atmosphere: annually, 484 tons of volatile organic compounds, 30 tons of hazardous air pollutants, 2.25 million tons of carbon monoxide, and hundreds of tons of particulate matter and nitrogen oxide.
If you live near or in the vicinity of the cracker, you may want to know what those emissions are and how they affect your health. What is it you smell (or don’t smell)? What is in the air you breathe at any given moment? And at what concentrations are these emissions harmful to your well-being and that of your family?
Two environmental groups— The Clean Air Council and the Environmental Integrity Project — believe that in order to be able to answer these questions, Shell needs to install a fenceline monitoring system that shares real-time emissions data with the community. They have appealed the permit that the cracker owner, Shell Chemical Appalachia, has obtained from the Pennsylvania Department of Environmental Protection [DEP] for the cracker.
Karl Koerner, an engineer who works for the Clean Air Council, said he thinks fenceline monitoring would provide the community with the information they need to keep tabs on Shell. "The more engaged the people are with Shell, the more active they are in talking with Shell and asking hard questions," he said. The idea is that the data would be accessible to community groups and residents on a website.
Shell hasn’t been willing to commit, at least not yet. The company cites that fenceline monitoring is not required by state or federal regulation. But, Shell spokesperson Ray Fisher wrote in an email, “Shell is open to considering the installation of fenceline monitoring and the sharing of fenceline monitoring information with the community.”
Because the matter is in litigation, DEP community relations coordinator Lauren Fraley couldn’t say much on the issue. However, Fraley wrote in an email that the DEP does not consider fenceline monitoring for volatile organic compounds [VOCs] or hazardous air pollutants to be necessary at the facility. In a June 2015 document, the DEP basically argued that Shell’s leak detection and repair program would be more superior in tracing and stopping fugitive gases from leaks and flares than a fenceline system.
The DEP is referring to the type of fenceline system that the Environmental Protection Agency [EPA] is going to require refineries to start using in 2018. This system monitors emissions of the known carcinogenic benzene. It is not quite what the Clean Air Council and Environmental Integrity Project are hoping for because it does not gather real-time data of many other emissions, and it doesn’t automatically share any data with the fenceline community.
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Independent of whether Shell Chemical Appalachia will install the fenceline monitoring system the environmentalist community desires, the company will be required to report to the DEP what the actual emissions of the cracker are on an annual basis, unless there is a malfunction.
If those emissions exceed the limits set in the air quality permit, DEP can dole out fines and demand operational changes. But that’s not enough, some environmentalists say.
The data Shell provides to the DEP will be mostly aggregate numbers that indicate the quantities of certain chemicals the cracker has been emitting over periods of weeks or months. The data will not show which gases, at which concentrations, are moving over the fenceline into the community at any given moment.
It’s not splitting hairs, according to some environmentalists. Take this example: The water that comes from your tap might have a comfortable average temperature over the week, but 10 seconds of scalding water will still cause burns. In the same manner, a short exposure to high concentrations of hazardous gases can be damaging.
A small group of citizen scientists from two communities on the San Francisco Bay in Contra Costa County are the pioneers in the field of fenceline monitoring.
“You have the right to know what goes up your nose,” said Jay Gunkelman, chief science officer of a company called Brain Science International. Gunkelman belongs to a dedicated group of citizens from Rodeo and Crockett, two towns about 25 miles north of Oakland. This group fought a hard, and ultimately successful, battle to have fenceline monitors installed around their neighbor, a refinery owned by Unocal.
“For a long time, we lived in what I would call benign neglect,” Gunkelman said. “We neglected the refinery and the refinery neglected the community.” It all changed dramatically in August 1994, when the refinery for 16 days spewed the toxic gas catacarb into the air, which residents think caused sore throats, nausea, headaches and dizziness among community members.
The residents of Rodeo and Crockett wanted security. Fenceline monitoring was practically unheard of in 1994, so a community working group began to design their own system. The system “was not just the leading edge when we designed it, it was the bleeding edge,” Gunkelman said.
The citizen scientists designed a fenceline monitoring system and demanded that the refinery would pay for the construction and maintenance. The owner of the refinery gave in when the citizens received support from Contra Costa County officials.
The system has been upgraded several times and has continued to function for 20 years at the refinery that today is owned by Phillips 66, a multinational energy company headquartered in Houston. Private contractor Argos Scientific operates and maintains the system, which is still considered by many environmentalists to be the gold standard for fenceline monitoring.
At www.fenceline.org, anyone can see the real-time data generated by the several technologies around two refineries, one in Rodeo and the other at a Chevron refinery in Richmond, 12 miles south of Rodeo. The website shows which gases come over the fence in what concentrations. It also shows the direction and force of the wind, an important indicator to show where the emissions are heading.
The system shoots laser beams of ultraviolet and infrared light along the fenceline. Gases that move through these beams absorb and reflect light in a manner that is specific for their chemical composition and concentration. The infrared laser serves mainly to discover hydrocarbons and VOCs, Gunkelman said. The UV laser is monitoring toxic emissions like benzene, carbon disulfide, toluene, xylene and sulfur dioxide.
The advantage of the system, according to Gunkelman, is that the data provide fenceline communities with the means to negotiate with plant operators: If the operator violates the air quality permit, the community group can confront the operator with actual leverage.
A few years after the system went into operation, the community working group of Rodeo and Crockett took their emission data to the operator of the refinery. “We showed them a printout of what they had emitted … we asked them to replace the valves bigger than 2 inches and replace them with a balance valve,” Gunkelman said. The refinery spent several million on new valves, but not until after the group threatened to start a class-action lawsuit, according to Gunkelman.
The fenceline monitors also function as a warning system. If you fill in your email address at www.fenceline.org, you’ll receive an email when concentrations of certain gases that come over the fenceline exceed a threshold. It serves as an advisory for nearby residents when it’s time to stay inside with the windows shut or leave the area altogether.
‘A baseline understanding’
Don Gamiles, the owner of Argos Scientific, the company that operates the system at the Phillips 66 refinery, believes Shell itself could benefit from fenceline monitoring.
"In a community with a refinery, any odor or emission that comes up, is blamed on the refinery," he said. "When we put up these fenceline systems, the numbers of complaints to the refinery actually go down. There are other sources of pollution and the the refinery can show it wasn't them."
The costs are relatively insignificant for a $6 billion facility. Gamiles said his company can install a state-of-the-art fenceline system like the one in Rodeo along one side of the cracker for somewhere between $150,000 and $300,000. Operation and maintenance would cost another $5,000 a month. He said it takes about three to five months to install and get the data online for the public.
“You do not necessarily have to surround the refinery completely,” Gamiles said. At the Phillips 66 refinery in Rodeo, he said the system covers two fencelines, the ones closest to the local population.
Under ideal circumstances, a fenceline system should start operating a couple of months before the cracker goes online.
"If you can put up a monitoring system before the refinery goes into operation, you can have a baseline understanding what the ambient air quality is before and after the construction of the refinery,” Gamiles said, explaining that it could also help to identify and address other sources of air pollution.
Shell is certainly familiar with fenceline monitoring and what it entails. Twenty years after the fenceline system in Rodeo-Crockett went into operation, the Bay Area Quality Management District has decided that all refineries in the Bay Area have to install fenceline monitoring. To meet that requirement, Shell is designing advanced fenceline monitoring for its refinery in Martinez, a town some 8 miles from Crockett in Contra Costa County.
The cracker is coming
Emission data aren’t worth much when you don’t have people who look at it and can understand it. However, Gunkelman doesn’t think every community group needs the same level of sophistication as the original group that designed the fenceline monitoring system in Rodeo-Crockett.
In 1994, that group had to start from scratch. Nowadays, there are several contractors with the capability to install and maintain complete systems.
Gunkelman thinks concerned residents and groups should meet quarterly to review reports and ensure everything is operating correctly.
He also suggested that fenceline communities look into placing air quality monitors in the neighboring community.
A fenceline monitoring system alone is not sufficient to catch all emissions: When the plant flares off certain chemicals, the gases may be too high up in the air to be caught by the laser beams along the fences. But the emissions still could affect the community.
Val Brkich, a freelance writer who lives in Beaver, posted a passionate piece against the cracker on his Facebook page about his concerns for his family and community. Brkich shared his motives: “My No. 1 concern was the chemicals and the smells and so on. I have two young kids and I’m worried about their health. It is already a fact that we have one of the worst air quality [levels] in the whole country.”
Brkich doesn’t see fenceline monitoring as a resolution because it only reports gases as they’re already entering the community. But it is something. “The only thing we can do now is stay informed, stay on top of what is happening, make sure that when they build this plant, that they follow the letter of the law,” he said.
The fenceline communities of Rodeo and Crockett got their monitoring system after a dangerous chemical leak in 1994. Residents of neighboring Richmond got fenceline monitoring after a 2012 fire.
Should Beaver County wait for its own mishap?
“Believe me,” said Don Gamiles, “the communities don’t want these systems to be turned off once they’re turned on. They really like this information.”
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