by Victoria Brandon, Redwood Chapter Chair
On Monday Sierra Club entities including Redwood Chapter joined representatives of other environmental organizations to express concern to the City of Benicia about the proposed Valero Crude-by-Rail Project. This proposed rail terminal could significantly impact the Suisun Marsh, emergency response time, traffic, and noise, and might also lead to increased supplies of very high-sulfur, low-quality crude oil from Canada’s tar sands winding up at Valero’s Benicia Refinery – with predictably negative effects on Bay Area air quality!
The city intends to base project approvals on a Mitigated Negative Declaration (MND) that was issued on May 31. This level of review is totally inadequate for a project with such great potential to harm air quality, public health, public safety, and the ecology of the area, with risks not only to residents of Benicia but also to the entire region. At the very minimum, a full Environmental Impact Report must be undertaken before allowing this project to forward. For a detailed evaluation of the failings of the MND, see the comment letter pasted below.
Benicia residents who want to find out more about the project are invited to attend “Crude Consensus,” a community meeting to be held from 6:30-8:30 p.m. on Tuesday July 9 at the Benicia Community Center, 370 East L Street, where the Natural Resources Defense Council will present expert research findings on potential environmental impacts, including local air pollution. Join the Benicia Good Neighbor Steering Committee and the NRDC to learn more about risks to local residents, and ways to participate in the City’s evaluation of the project. Snacks and refreshments will be provided.
RSVP at http://bit.ly/10rNGvP so we know how many to expect
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Then on July 11 everyone in the region who has concerns about this project is encouraged to “Stand with Benicia” by attending the regular meeting of the Benicia Planning Commission, which will hold a formal hearing on the Crude-by-Rail project at 7.00 p.m. on Thursday July 11 at Benicia City Hall, 250 East L Street. The Commissioners are being asked to assess the project’s potential effects on the environment, WITHOUT the information that only a full Environmental Impact Report can provide. Stand up for Benicia by commenting on the record during the meeting, and be sure to request that an EIR be conducted.
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The comments below were submitted to the City of Benicia on July 1, 2013
Re: Notice of Intent to Adopt a Mitigated Negative Declaration for the Valero Crude by Rail Project
We, the undersigned, are writing to you on behalf of our organizations and our many thousands of members to express concern over the potential for grave environmental and public health impacts of the proposed Valero Crude by Rail Project, for which a proposed Mitigated Negative Declaration (MND) was issued on May 31st, 2013. The MND for this project is seriously deficient in its environmental analysis in many regards, including adverse impacts to air quality, public health, public safety, noise, general hazards and ecological risks, not only to residents of Benicia but also to the entire San Francisco Bay Area. At a minimum, a full Environmental Impact Review must be performed before this project can move forward.
The MND fails to address potentially significant air pollution and other impacts caused by refining additional amounts of lower quality crude oil—including from the Canadian tar sands—that could be facilitated by the project. Valero has been clear about its intentions to increase Western Canadian crude oil imports into its California refineries in remarks to investors, and independent market research confirms that the proposed Benicia facility is likely to facilitate imports of significant volumes of tar sands crude blends. The probability of the project facilitating additional, lower quality crude supplies and the resulting impacts on air quality and public health are not discussed or evaluated in the MND.
Refining increased volumes of the Western Canadian diluted bitumen products, which the proposed facility would make feasible, presents unique and significant air quality, public health, safety and ecological and water quality impacts. The following impacts would far exceed the impacts of conventional crude oil feedstocks:
- The “diluent” used to make heavy “bitumen” or tar sands flow into and out of railcars contains highly volatile organic chemicals, including extremely toxic ones like benzene, at much higher concentrations than conventional crude oil; and is likely to be released during transport and refining.
- The heavy bitumen component of the tar sands oil contains many toxic constituents including heavy metals such as lead at much higher concentrations than conventional crude oil and which are likely to be released during the refining process.
- The heavy bitumen is also much more energy intensive to refine than conventional crude. Due to the composition of heavier, longer chain hydrocarbons, these denser crude oils require greater use of heaters, boilers, hydro-treating and cracking and greater hydrogen use, all of which creates greater emissions of smog- and soot-forming pollutants and toxic chemicals.
- Dilbits are associated with greater levels of strong odors due to their composition including a variety of sulfur containing compounds, such as mercaptans, at higher levels.
- Refining of heavy bitumen or tar sands leads to increased coke production, which in itself is a hazardous compound leading to storage and disposal issues including the potential for coke dust from storage piles to impact nearby residents, as has been documented near the Marathon refinery in Detroit, Michigan.
- Dilbits are more corrosive than conventional crude oil, increasing the risk of refinery accidents similar to the August 6, 2012 fire at Chevron Richmond, for which lower quality crude oil was found to be a contributing factor.
- Rail car spills of dilbit would be catastrophic to the fragile San Francisco Bay Delta. This is because the diluent – typically natural gas condensates acting as a solvent – helps the oil spread on surface waters. The diluent typically evaporates leaving the very heavy bitumen to sink, creating an exceptionally difficult and expensive clean-up. This was found to be the case in Kalamazoo, Michigan after a 2010 pipeline ruptured, releasing bitumen and causing well documented and widespread public health impacts and lasting contamination to this day (three years later).
The MND also fails to fully consider the noise impacts of this project, which will bring four 50-car trains to the refinery each day, with operations predominantly at night but potentially at all hours (“24 hours per day/7 days per week/365 days per year”). In addition to noise impacts, the additional half hour each day of blocked access due to trains crossing the Park Road intersection would be a nuisance and potentially a safety issue to the nearby community. A grade separation should be evaluated as potential mitigation. The analysis fails to consider the horns and noise of the four additional trains going through at-grade crossings, particularly at night when most of the activity is expected. Noise has been associated with many health impacts such as heart disease and stroke, as well as worsening children’s mental health, concentration, and classroom behavior at school. An Environmental Impact Review must gauge existing levels of refinery noise and related communication interference, sleep interference or physiological responses; and predict future levels associated with the Project. Finally, we note that with respect to the level of rail service proposed here (4 50-car trains per day), the City of Benicia needs to demonstrate that it has the authority to impose and fully enforce such a limit consistently with federal law.
Due to all of the serious potential impacts from the Valero Crude by Rail project listed here, the lack of sufficient information to properly evaluate the project and the potential for serious and irreversible harm to the greater San Francisco Bay Area caused by the import of exceptionally toxic substances through this Project, we urge the City of Benicia to perform a thorough Environmental Impact Review evaluating these impacts and all appropriate mitigation options, before proceeding. The significant environmental impacts of this proposed project must be fully mitigated before it can be approved. We hereby reference the detailed and expert comments submitted by the Natural Resources Defense Council on July 1, 2013; and strongly urge your consideration of our concerns.
- Greg Karras, Senior Scientist, Communities for a Better Environment
- Denny Larson, Executive Director, Global Community Monitor
- Michael Marx, Director, Beyond Oil Campaign, Sierra Club
- Edward A. Mainland, Co-Chair, Energy-Climate Committee, Sierra Club California
- Michelle Myers, Director, Sierra Club San Francisco Bay Chapter
- Victoria Brandon, Chair, Sierra Club Redwood Chapter
- David W. Campbell, Secretary-Treasurer, United Steelworkers Local 675
- David Schonbrunn, President, Transportation Solutions Defense and Education Fund
- Azibuike Akaba, Policy Analyst, Regional Asthma Management & Prevention
- Jill Ratner, President, Rose Foundation for Communities and the Environment
- Jess Dervin-Ackerman, Chair, 350 Bay Area